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2018 (8) TMI 520 - HC - Income TaxReopening of assessment - invalid notice - contention of assessee is that the notice was not issued with the prior sanction of the Joint Commissioner, but sanction was accorded by the Additional Commissioner therefore, notice u/s 148 issued by the A.O. was without jurisdiction - Held that:- Section 2 of the Act is Definitions Section. Clause (28C) of Section 2 of the Act defines the word “Joint Commissioner” and explains it means a person appointed to be a Joint Commissioner of Income Tax or an Additional Commissioner of Income Tax under sub-section (1) of Section 117. Thus, the Joint Commissioner includes an Additional Commissioner as well. See Dharam Pal Singh Rao Vs. Income-Tax Officer and another, [2004 (8) TMI 88 - ALLAHABAD HIGH COURT] - decided against assessee
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