https://www.taxtmi.com/caselaws?id=9254 Reopening under section 34(1)(a) of the Indian Income-tax Act, 1922 was treated as jurisdictionally invalid because the Income-tax Officer had to record reasons and, in the relevant class of cases, obtain the Commissioner's satisfaction before issuing notice. The Court applied the principle that these statutory requirements were conditions precedent, not mere procedural steps. As the requisite approval or sanction was not obtained and the recorded reasons were not forwarded for consideration, the reassessment notice and consequent proceedings were held bad in law and invalid at the root. en-us Thu, 30 Aug 1973 00:00:00 +0530 Sat, 20 Jun 2009 16:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9254 Reopening under section 34(1)(a) of the Indian Income-tax Act, 1922 was treated as jurisdictionally invalid because the Income-tax Officer had to record reasons and, in the relevant class of cases, obtain the Commissioner's satisfaction before issuing notice. The Court applied the principle that these statutory requirements were conditions precedent, not mere procedural steps. As the requisite approval or sanction was not obtained and the recorded reasons were not forwarded for consideration, the reassessment notice and consequent proceedings were held bad in law and invalid at the root. Case-Laws Income Tax Thu, 30 Aug 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9254