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2022 (4) TMI 1530 - HC - Income TaxValidity of reopening of assessment u/s 147 - reopening beyond period of four years - Invalid approval u/s 151 - sanction has been given by Additional Commissioner of Income Tax (ACIT), Joint Commissioner of Income Tax and not Principal Commissioner - HELD THAT:- Since four years had expired from the end of the relevant assessment year as provided under Section 151(1) of the Act, it is only the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner who could have accorded the approval and not the Joint Commissioner of Income Tax. On this ground alone, we will have to set aside the impugned notice. Consequently, the order on objections passed also has to be quashed and set aside.
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