https://www.taxtmi.com/caselaws?id=176438 Prior sanction for reassessment under Section 34 requires the Income-tax Officer to record reasons and obtain the Commissioner's approval, but the statute does not require those reasons to be communicated to the assessee, and the assessee cannot challenge their sufficiency in that proceeding. The notice initiating reassessment also need not state at the outset whether the eventual reassessment will be confined to four years or eight years, because that statutory limit operates at the assessment stage after investigation of the relevant facts. The commentary therefore explains that the initiating notice is valid without disclosing the sanction reasons or fixing the ultimate limitation period in advance. en-us Fri, 22 Jan 1954 00:00:00 +0530 Tue, 22 Dec 2015 17:25:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176438 Prior sanction for reassessment under Section 34 requires the Income-tax Officer to record reasons and obtain the Commissioner's approval, but the statute does not require those reasons to be communicated to the assessee, and the assessee cannot challenge their sufficiency in that proceeding. The notice initiating reassessment also need not state at the outset whether the eventual reassessment will be confined to four years or eight years, because that statutory limit operates at the assessment stage after investigation of the relevant facts. The commentary therefore explains that the initiating notice is valid without disclosing the sanction reasons or fixing the ultimate limitation period in advance. Case-Laws Income Tax Fri, 22 Jan 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176438