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Reassessment proceedings invalidated due to improper sanctioning authority. Sanction accorded by Principal Commissioner instead of Principal Chief Commissioner as mandated for cases beyond three years u/s 151(ii). Proviso to Section 151 inserting revised sanctioning authorities effective April 1, 2023, inapplicable. Impugned order and notice quashed, decided in assessee's favor, following Siemens Financial Services Private Limited case.
Reassessment proceedings invalidated due to improper sanctioning authority. Sanction accorded by Principal Commissioner instead of Principal Chief Commissioner as mandated for cases beyond three years u/s 151(ii). Proviso to Section 151 inserting revised sanctioning authorities effective April 1, 2023, inapplicable. Impugned order and notice quashed, decided in assessee's favor, following Siemens Financial Services Private Limited case.
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