Impugned notice quashed due to lack of sanction for reopening assessment beyond 3 years, violating Section 151(ii). Notification can't override statute.

Sanction by specified authority not obtained as per amended provisions of Section 151 for reopening assessment beyond 3 years, rendering impugned notice invalid; notification under TOLA cannot override statutory provisions; impugned notice quashed being contrary to Section 151(ii) requiring sanction from higher authority for reopening beyond 3 years. .....

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