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2010 (12) TMI 164 - AT - Income TaxSanction for issue of notice - Assessee contended that since the original assessment order was passed under section 143(3) of the Act and notice under section 148 was issued after the expiry of 4 years as per proviso to section 151(1), the AO must have taken the sanction of the CCIT or CIT to reopen a completed assessment - Accordingly, there is no alternate except to agree with the view taken by the ld. J.M. and answer the question that in the given facts and circumstances of the case, the requisite mandatory sanction under section 151 of the Act for issuing notice under section 148 has not been obtained by the Assessing Officer
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