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2023 (12) TMI 401 - AT - Income TaxValidity of reopening of assessment u/s 147 - prior sanction of approval u/s 151 of the Act from the competent authority not taken - Exemption u/s 10(26BBB) denied - HELD THAT:- We find that prior sanction of approval u/s 151 of the Act from the competent authority is mandatory before the reopening of assessment. As it has been duly confirmed that no approval U/s 151 of the Act is on record for the years under consideration, the assumption of jurisdiction U/s 147 of the Act becomes void ab initio. Accordingly, the entire reassessment proceedings are hereby quashed. Assessee appeal allowed.
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