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of <h1>SC affirms invalid income tax reassessment for AY 2016-17 due to wrong Section 151 sanction, Section 147</h1> SC upheld the HC's decision quashing the reassessment proceedings for AY 2016-2017 under section 147. The HC had held that the mandatory prior approval ... Validity of reopening of assessment u/s 147 - improper sanction accorded u/s 151 - As decided by HC [2023 (9) TMI 1702 - BOMBAY HIGH COURT] for Assessment Year 2016-2017, the sanction should have been given u/s 151(ii) and not u/s 151(i) and consequently the sanction is invalid. The Court has stated that in view of the invalid sanction, the notice issued itself will be invalid and has to be quashed. HELD THAT:- We find no good ground to interfere with the impugned order passed by the High Court. Special Leave Petition is, accordingly, dismissed. The Supreme Court, exercising its jurisdiction under Article 136, declined to interfere with the judgment of the High Court. After hearing counsel for both sides and examining the record, the Court held that it found 'no good ground to interfere with the impugned order passed by the High Court.' Consequently, the Special Leave Petition was dismissed. The Court did not enter into a detailed discussion of the merits or elaborate on the High Court's reasoning, implicitly affirming that no error warranting interference in special leave jurisdiction was made out. All pending applications were also disposed of.
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