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        Case ID :
        Income Tax

        Validity of reopening under section 147/148 is contested on the...

        Validity of income-tax reopening notices where sanction by wrong authority renders the notice invalid and leads to quashing.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                Validity of reopening under section 147/148 is contested on the ground that the sanction required from the competent authority was not obtained; the notice issued in AY 2015-16 on 28 March 2021 falls within the temporal ratio of the cited Supreme Court authority, but was quashed because the sanction stated on the notice was from the CIT (Exemption) rather than the Joint Commissioner mandated by law, and Revenue cannot contradict the express language of the notice regarding whose satisfaction was obtained. The necessity for sanction by the specific authority is determinative, leading to invalidation of the notice.
                                Note: It is a system-generated summary and is for quick reference only.
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