<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>Reassessment proceedings initiated beyond 3 years sans sanction from authorized authority u/s 151(ii) rendered invalid.</title>
    <link>https://www.taxtmi.com/highlights?id=80040</link>
    <description>Reassessment proceedings u/s 148 were sought to be undertaken more than three years after the end of the relevant Assessment Year. Sanction was required to be granted u/s 151(ii) of the Act since the period exceeded three years. However, the sanction was granted by the Principal Commissioner of Income-tax-3, who was not the specified authority empowered u/s 151(ii). Section 151 contains an inherent check and balance, requiring application of mind by more senior authorities when reopening is initiated after a longer period. Since the sanction was not granted by the authority having jurisdiction u/s 151(ii), the High Court disposed of the petition on this ground without expressing any opinion on other facets of law and issues raised.</description>
    <language>en-us</language>
    <pubDate>Fri, 02 Aug 2024 08:13:11 +0530</pubDate>
    <lastBuildDate>Fri, 02 Aug 2024 08:13:11 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=762654" rel="self" type="application/rss+xml"/>
    <item>
      <title>Reassessment proceedings initiated beyond 3 years sans sanction from authorized authority u/s 151(ii) rendered invalid.</title>
      <link>https://www.taxtmi.com/highlights?id=80040</link>
      <description>Reassessment proceedings u/s 148 were sought to be undertaken more than three years after the end of the relevant Assessment Year. Sanction was required to be granted u/s 151(ii) of the Act since the period exceeded three years. However, the sanction was granted by the Principal Commissioner of Income-tax-3, who was not the specified authority empowered u/s 151(ii). Section 151 contains an inherent check and balance, requiring application of mind by more senior authorities when reopening is initiated after a longer period. Since the sanction was not granted by the authority having jurisdiction u/s 151(ii), the High Court disposed of the petition on this ground without expressing any opinion on other facets of law and issues raised.</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Fri, 02 Aug 2024 08:13:11 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=80040</guid>
    </item>
  </channel>
</rss>