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2017 (2) TMI 997 - ITAT MUMBAIValidity of reopening of assessment - sanction of ld. CIT was obtained instead of JCIT as provided u/s 151 - Held that:- There was no new material before the AO for re-opening of the concluded assessment. The re-opening was made beyond the four year from the end of relevant assessment year. Moreover, there was no proper sanction from the competent authority for issue of notice as provided u/s 151 of the Act. Thus, in view of the above discussion, the re-opening of assessment u/s 147 is bad-in-law. - Decided in favour of assessee.
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