https://www.taxtmi.com/caselaws?id=38915 Statutory sanction for reopening under section 34(1)(a) of the Indian Income-tax Act, 1922 was treated as duly granted where the official record, including the assessing officer's proposal, the Commissioner's forwarding memo, the Board's telegram and the authenticated Form C endorsement, showed approval. Once that official act was established, the presumption of regularity under section 114 of the Evidence Act applied, and a vague or belated challenge without specific particulars did not dislodge it. The challenge was also undermined by the successor authority position and the absence of the necessary impleadment, so the plea of non-compliance with the sanction requirement was not made out. en-us Mon, 20 May 1974 00:00:00 +0530 Sat, 10 Apr 2010 13:13:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38915 Statutory sanction for reopening under section 34(1)(a) of the Indian Income-tax Act, 1922 was treated as duly granted where the official record, including the assessing officer's proposal, the Commissioner's forwarding memo, the Board's telegram and the authenticated Form C endorsement, showed approval. Once that official act was established, the presumption of regularity under section 114 of the Evidence Act applied, and a vague or belated challenge without specific particulars did not dislodge it. The challenge was also undermined by the successor authority position and the absence of the necessary impleadment, so the plea of non-compliance with the sanction requirement was not made out. Case-Laws Income Tax Mon, 20 May 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38915