2021 (12) TMI 1504

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..... evenue in this review petition is that this Court in its order [ 2019 (12) TMI 829 - ORISSA HIGH COURT] erred in drawing a distinction between an Additional Commissioner and Commissioner in terms of their authority, the point involved was that for the purpose of Section 151(1) of the Income Tax Act, 1961 since the reopening of the assessment was beyond 4 years, it had to have the prior approval of .....

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