Reopening of assessment u/s 147 - reason recorded by the AO or the issuance of notice u/s 148 does not...

Reopening of assessment u/s 147 - reason recorded by the AO or the issuance of notice u/s 148 does not give any indication of obtaining sanction from the ACIT/JCIT though in terms of the provision of section 151 it is the pre-condition for initiating proceeding u/s 148 - Non-compliance is a defect which is admittedly not curable - entire proceeding void in law and liable to be set aside .....

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