Reassessment Notice Validity Hinges on Timing and Proper Section 151 Approval for Tax Proceedings

HC held that the specified authority for approval under Section 151 depends on whether the reassessment notice under Section 148 was issued within three years from the end of the relevant assessment year. The court consistently interpreted that the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA) extension does not impact the determination of the mandatory approval authority. Based on this legal principle, the court set aside the impugned notice, thereby allowing the assessee's appeal and invalidating the reassessment proceedings due to procedural non-compliance with Section 151 approval requirements. .....

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