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2022 (7) TMI 1459 - BOMBAY HIGH COURTReopening of assessment - notice issued after the expiry of period of four years - approval from competent authority - HELD THAT:- On a reading of Section 151 it is clear that a notice under Section 148 of the Act, 1961 cannot be issued after the expiry of period of four years from the end of the relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner was satisfied, on the reasons recorded by the A.O., that it was a ft case for the issue of such a notice. In the present case, it is clear that assessment year under consideration was 2015-16 and, therefore, the notice impugned was admittedly beyond the four years period for which the approval ought to have been granted by any one of the aforementioned four authorities and not by the Joint Commissioner. It is clear that, the A.O. fell in error in holding that the case at hand fell within the four years period, from the end of the assessment year under consideration, which on the face of it appears to be erroneous. WP allowed.
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