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    <title>2024 (3) TMI 1479 - BOMBAY HIGH COURT</title>
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    <description>A reassessment notice under Section 148 and the order under Section 148A(d) were invalid where the assessment year was beyond three years from the relevant date and sanction under Section 151(ii) had to be accorded by the Principal Chief Commissioner of Income Tax. Sanction was instead granted by the Principal Commissioner of Income Tax, so the statutory approval was by the wrong authority. The proviso inserted in Section 151 from 1 April 2023 did not apply. The reassessment proceedings were therefore invalid and the notice and order were quashed.</description>
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      <description>A reassessment notice under Section 148 and the order under Section 148A(d) were invalid where the assessment year was beyond three years from the relevant date and sanction under Section 151(ii) had to be accorded by the Principal Chief Commissioner of Income Tax. Sanction was instead granted by the Principal Commissioner of Income Tax, so the statutory approval was by the wrong authority. The proviso inserted in Section 151 from 1 April 2023 did not apply. The reassessment proceedings were therefore invalid and the notice and order were quashed.</description>
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