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2012 (11) TMI 860 - HC - Income TaxSanction of Authority u/s 151 before issue of Notice u/s 148 - held that:- No Notice can be issued after expiry of four years from the end of the relevant assessment year, unless the Chief Commissioner or the Commissioner is satisfied on the reasons supported by the assessing officer that it is a fit case for issuance of notice - no substantial question of law involved in this appeal for its admission Proviso to Section 151 empowers the Chief Commissioner or the Commissioner of the Income Tax Act to accord sanction and this power has not been vested to any other officer irrespective of fact as to whether the assessing officer is Assistant Commissioner or the Deputy Commissioner or any other officer.- appeal is dismissed. Decision in case of [Shashi Kant Garg vs. Commissioner of Income Tax & others 2005 (8) TMI 81 - ALLAHABAD HIGH COURT] followed.
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