https://www.taxtmi.com/caselaws?id=463211 A reassessment notice issued after four years from the end of the relevant assessment year required prior approval from the statutorily designated higher authority; approval only by the Joint Commissioner did not satisfy section 151(1), so the notice was without jurisdiction. Although the notice was dated 31.03.2021, electronic transmission and receipt on 01.04.2021 meant issuance occurred under the amended reopening regime introduced by the Finance Act, 2021, and the pre-amended framework could not be applied; the reassessment action was therefore vitiated. The Tribunal also stated that section 40A(2)(b) does not apply to a co-operative society, so reopening on that basis was unsustainable. en-us Wed, 04 Sep 2024 00:00:00 +0530 Thu, 14 Aug 2025 16:09:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463211 A reassessment notice issued after four years from the end of the relevant assessment year required prior approval from the statutorily designated higher authority; approval only by the Joint Commissioner did not satisfy section 151(1), so the notice was without jurisdiction. Although the notice was dated 31.03.2021, electronic transmission and receipt on 01.04.2021 meant issuance occurred under the amended reopening regime introduced by the Finance Act, 2021, and the pre-amended framework could not be applied; the reassessment action was therefore vitiated. The Tribunal also stated that section 40A(2)(b) does not apply to a co-operative society, so reopening on that basis was unsustainable. Case-Laws Income Tax Wed, 04 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463211