2022 (4) TMI 1530

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..... not Principal Commissioner - HELD THAT:- Since four years had expired from the end of the relevant assessment year as provided under Section 151(1) of the Act, it is only the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner who could have accorded the approval and not the Joint Commissioner of Income Tax. On this ground alone, we will have to set aside t .....

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..... of Income Tax and not Principal Commissioner. Since the re-opening has been proposed more than four years after the end of the expiry of relevant assessment year as held by us in J M Financial and Investment Consultancy Services Private Limited vs. Assistant Commissioner of Income Tax, Circle 3(2)(1) and Ors. Writ Petition No. 1050 of 2022 Dated 4th April, 2022 the Taxation and Other Laws .....

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