https://www.taxtmi.com/caselaws?id=755506 The Bombay HC quashed a reassessment notice issued under Section 148 for AY 2016-17 dated 30 July 2022. The court held that since the notice was issued after three years from the end of the assessment year, sanction under Section 151(ii) was required from Principal Chief Commissioner/Principal Director General or Chief Commissioner/Director General. However, sanction was obtained only from Principal Commissioner as per Section 151(i), which applies to cases within three years. The court ruled that proper sanction under the applicable provision was not obtained, rendering the notice bad in law. The respondent's reliance on TOLA notification was rejected as subordinate legislation cannot override parliamentary statute. en-us Tue, 02 Jul 2024 00:00:00 +0530 Fri, 12 Jul 2024 13:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755506 The Bombay HC quashed a reassessment notice issued under Section 148 for AY 2016-17 dated 30 July 2022. The court held that since the notice was issued after three years from the end of the assessment year, sanction under Section 151(ii) was required from Principal Chief Commissioner/Principal Director General or Chief Commissioner/Director General. However, sanction was obtained only from Principal Commissioner as per Section 151(i), which applies to cases within three years. The court ruled that proper sanction under the applicable provision was not obtained, rendering the notice bad in law. The respondent's reliance on TOLA notification was rejected as subordinate legislation cannot override parliamentary statute. Case-Laws Income Tax Tue, 02 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755506