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    <title>2023 (12) TMI 1454 - BOMBAY HIGH COURT</title>
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    <description>The HC quashed income tax reopening proceedings after finding the approval under Section 151 of the Income Tax Act was granted without application of mind by the officers involved. The court determined that the Principal Commissioner lacked jurisdiction to approve reopening beyond three years, as only the Principal Chief Commissioner has such authority. The approval form contained errors referencing incorrect statutory provisions, which should have alerted officers to jurisdictional issues. Consequently, notices issued under Sections 148A(b), 148A(d), and 148 were declared invalid due to the flawed approval process and procedural violations.</description>
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      <title>2023 (12) TMI 1454 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=462611</link>
      <description>The HC quashed income tax reopening proceedings after finding the approval under Section 151 of the Income Tax Act was granted without application of mind by the officers involved. The court determined that the Principal Commissioner lacked jurisdiction to approve reopening beyond three years, as only the Principal Chief Commissioner has such authority. The approval form contained errors referencing incorrect statutory provisions, which should have alerted officers to jurisdictional issues. Consequently, notices issued under Sections 148A(b), 148A(d), and 148 were declared invalid due to the flawed approval process and procedural violations.</description>
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      <pubDate>Wed, 13 Dec 2023 00:00:00 +0530</pubDate>
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