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2022 (7) TMI 1458 - BOMBAY HIGH COURTReopening of assessment u/s 147 - valid Approval u/s 151 - notice was being issued beyond the four years period prescribed - HELD THAT:- Since the issue of grant of approval by an authority, as prescribed u/s 151 of the Act goes to the root of the matter, we wish to deal only with the said issue and hold that even in the present case, the approval ought to have been granted by either the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner and not by the Additional Commissioner of Income tax. Since the notice was being issued beyond the four years period prescribed under the un-amended provisions of section 151(1) of the Act, it ought to have the satisfaction accorded by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner of Income Tax which is not so in the present case.
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