https://www.taxtmi.com/caselaws?id=360987 The dominant issue was whether reopening under s.147 beyond four years was vitiated for want of valid sanction under s.151(1). The HC held that s.151(1) mandates satisfaction of the competent higher authority on the reasons recorded by the AO before issuance of notice under s.148, and this safeguard was complied with: the Addl. CIT made remarks on the sanction proforma and separately communicated satisfaction by letter, constituting an integrated exercise evidencing application of mind on the recorded reasons and material. Consequently, the challenge to the reopening notice failed and the petition was decided against the assessee. en-us Wed, 09 May 2018 00:00:00 +0530 Fri, 26 Dec 2025 11:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=360987 The dominant issue was whether reopening under s.147 beyond four years was vitiated for want of valid sanction under s.151(1). The HC held that s.151(1) mandates satisfaction of the competent higher authority on the reasons recorded by the AO before issuance of notice under s.148, and this safeguard was complied with: the Addl. CIT made remarks on the sanction proforma and separately communicated satisfaction by letter, constituting an integrated exercise evidencing application of mind on the recorded reasons and material. Consequently, the challenge to the reopening notice failed and the petition was decided against the assessee. Case-Laws Income Tax Wed, 09 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=360987