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Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether the unsigned sanction under Section 151 of the Income-tax Act, 1961 vitiated the order under Section 148A(d) and the consequential reassessment and penalty proceedings.
Analysis: The sanction under Section 151 was not disputed and the produced approval was unsigned. Since valid sanction was a jurisdictional prerequisite for passing the order under Section 148A(d), the defect went to the root of the proceedings. The subsequent notice under Section 148, the order under Section 147, and the penalty notices were all founded on the defective sanction and could not be sustained.
Conclusion: The order under Section 148A(d) and all consequential proceedings were set aside, and the matter was remitted to the stage after the Section 148A(b) notice with liberty to obtain proper sanction and proceed afresh.
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