Sanction by specified authority not obtained as per amended ...
Impugned notice quashed due to lack of sanction for reopening assessment beyond 3 years, violating Section 151(ii). Notification can't override statute.
Case Laws Income Tax
July 13, 2024
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.
View Source