https://www.taxtmi.com/caselaws?id=756406 The ITAT PUNE held that a notice u/s. 148 issued for A.Y. 2007-08 on 28.03.2014 was invalid due to improper sanction. Since more than four years had elapsed from the relevant assessment year, section 151(1) mandated prior sanction from Principal Chief Commissioner, Chief Commissioner, Principal Commissioner, or Commissioner. However, the AO obtained sanction only from Joint Commissioner, which was insufficient. The tribunal ruled that statutory requirements must be strictly followed, and sanction from wrong authority vitiates the notice. This defect was held non-curable under section 292B. Decision favored the assessee. en-us Wed, 31 Jul 2024 00:00:00 +0530 Thu, 01 Aug 2024 17:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756406 The ITAT PUNE held that a notice u/s. 148 issued for A.Y. 2007-08 on 28.03.2014 was invalid due to improper sanction. Since more than four years had elapsed from the relevant assessment year, section 151(1) mandated prior sanction from Principal Chief Commissioner, Chief Commissioner, Principal Commissioner, or Commissioner. However, the AO obtained sanction only from Joint Commissioner, which was insufficient. The tribunal ruled that statutory requirements must be strictly followed, and sanction from wrong authority vitiates the notice. This defect was held non-curable under section 292B. Decision favored the assessee. Case-Laws Income Tax Wed, 31 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756406