Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
A reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
A reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
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