https://www.taxtmi.com/caselaws?id=355347 A notice issued under section 148 beyond four years from the end of the relevant assessment year requires prior approval under section 151(1), and that safeguard applies even where the original assessment was completed by an Assessing Officer. The provision, read with the amended scheme and the administrative circular, was construed to require higher-level satisfaction before reopening, in order to maintain parity between scrutiny and non-scrutiny assessments and avoid a gap in the statutory framework. On that interpretation, the notice was invalid for want of the requisite approval, and the question of law was answered against the Revenue and in favour of the assessee. en-us Thu, 08 Feb 2018 00:00:00 +0530 Thu, 08 Mar 2018 14:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=355347 A notice issued under section 148 beyond four years from the end of the relevant assessment year requires prior approval under section 151(1), and that safeguard applies even where the original assessment was completed by an Assessing Officer. The provision, read with the amended scheme and the administrative circular, was construed to require higher-level satisfaction before reopening, in order to maintain parity between scrutiny and non-scrutiny assessments and avoid a gap in the statutory framework. On that interpretation, the notice was invalid for want of the requisite approval, and the question of law was answered against the Revenue and in favour of the assessee. Case-Laws Income Tax Thu, 08 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=355347