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2005 (8) TMI 81 - ALLAHABAD HIGH COURT
Sanction of the Chief Commissioner or the Commissioner of Income-tax before issuing the notice - interpreting the provisions of sub-section (2) of section 151 -assessment/ reassessment has been completed under sub-section (3) of section 143 or section 147 of the Act and the notice under section 148 of the Act, dated September 12, 2000, had been issued much after the expiry of the period of four years from the end of the relevant assessment years - it is well-settled that a notice issued without obtaining the prior sanction of the authority mentioned in the provisions of section 151, whether it is the proviso to sub-section (1) or sub-section (2), would be invalid and the entire proceeding taken in pursuance thereof is liable to be quashed as the same would be without jurisdiction. - impugned notices are invalid, cannot be sustained and are hereby set aside. Consequently, all proceedings taken in pursuance of these notices are also set aside.