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HC held that the Section 148 notice for reassessment was invalid due to procedural non-compliance. The notice was issued beyond the three-year limitation period for assessments exceeding Rs. 50 lakhs, requiring mandatory approval from Principal Chief Commissioner under Section 151(ii). Since approval was obtained from Principal Commissioner under Section 151(i) instead of the requisite authority, the notice was jurisdictionally defective. The court consequently quashed the reassessment proceedings, thereby allowing the assessee's appeal and rendering the entire reassessment process null and void.
HC held that the Section 148 notice for reassessment was invalid due to procedural non-compliance. The notice was issued beyond the three-year limitation period for assessments exceeding Rs. 50 lakhs, requiring mandatory approval from Principal Chief Commissioner under Section 151(ii). Since approval was obtained from Principal Commissioner under Section 151(i) instead of the requisite authority, the notice was jurisdictionally defective. The court consequently quashed the reassessment proceedings, thereby allowing the assessee's appeal and rendering the entire reassessment process null and void.
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