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ITAT allowed the appeal, holding the reassessment notice invalid because it was issued after the three-year limitation period without sanction by the authority specified in section 151(ii). The prior approval recorded from the Principal Commissioner was inadequate where the notice was issued beyond three years from the end of the relevant AY; sanction in such cases must come from the Principal Chief Commissioner or Principal Director General, or, if those posts do not exist, from the Chief Commissioner or Director General. Consequently, the reopening lacked lawful authority and any consequential proceedings were quashed, with the taxpayer's challenge to the validity of the assessment sustained.
ITAT allowed the appeal, holding the reassessment notice invalid because it was issued after the three-year limitation period without sanction by the authority specified in section 151(ii). The prior approval recorded from the Principal Commissioner was inadequate where the notice was issued beyond three years from the end of the relevant AY; sanction in such cases must come from the Principal Chief Commissioner or Principal Director General, or, if those posts do not exist, from the Chief Commissioner or Director General. Consequently, the reopening lacked lawful authority and any consequential proceedings were quashed, with the taxpayer's challenge to the validity of the assessment sustained.
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