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Reassessment initiated after the three-year period required approval from the higher authorities specified by section 151(2); approval recorded from a Principal Commissioner did not satisfy that statutory requirement, so the notice under section 148 and the reassessment order under section 147 read with section 144 were invalid and quashed. Consequential penalty orders founded on the quashed reassessment were also held invalid and quashed. The Tribunal did not decide the remaining merits-based grounds of appeal.
Reassessment initiated after the three-year period required approval from the higher authorities specified by section 151(2); approval recorded from a Principal Commissioner did not satisfy that statutory requirement, so the notice under section 148 and the reassessment order under section 147 read with section 144 were invalid and quashed. Consequential penalty orders founded on the quashed reassessment were also held invalid and quashed. The Tribunal did not decide the remaining merits-based grounds of appeal.
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