Specified authority for reopening assessments under sections 148/148A narrowed to additional or joint tax commissioners. Sanction to issue notices for reopening under sections 148 and 148A is determined by the specified authority under section 151. From 01.09.2024 the competent sanctioning officers are limited to Additional Commissioner/Additional Director or Joint Commissioner/Joint Director. Previously, where three years or less had elapsed sanction rested with Principal Commissioner/Principal Director or Commissioner/Director, and where more than three years had elapsed sanction rested with higher tier authorities; the three year computation must account for exclusions or extensions under the limitation provisos, and Finance Act 2021 reduced reopening time limits.
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Provisions expressly mentioned in the judgment/order text.
Specified authority for reopening assessments under sections 148/148A narrowed to additional or joint tax commissioners.
Sanction to issue notices for reopening under sections 148 and 148A is determined by the specified authority under section 151. From 01.09.2024 the competent sanctioning officers are limited to Additional Commissioner/Additional Director or Joint Commissioner/Joint Director. Previously, where three years or less had elapsed sanction rested with Principal Commissioner/Principal Director or Commissioner/Director, and where more than three years had elapsed sanction rested with higher tier authorities; the three year computation must account for exclusions or extensions under the limitation provisos, and Finance Act 2021 reduced reopening time limits.
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