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2019 (12) TMI 829 - HC - Income TaxReopening of assessment u/s 147 - Sanction for issue of notice u/s 151 - HELD THAT:- Admittedly, the impugned notice u/s 148 was issued in respect of Assessment Year 2002-03, which is clearly after four years from the end of the relevant assessment year. The contention of learned counsel for the parties is not acceptable. The Additional Commissioner is not equivalent to the rank of Commissioner or any other designation as defined under Section 151 (1) of the Act. Therefore, the impugned notice (Annexure-1), which has been issued to the petitioner, is bad in law and is required to be quashed and the same is quashed. Rule is made absolute to the aforesaid extent.
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