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    <title>2024 (4) TMI 1319 - BOMBAY HIGH COURT</title>
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    <description>Approval under Section 151 was found invalid where reassessment proceedings were initiated beyond the period prescribed in Section 149(1)(b). The approval form referred to Section 149(1)(b) for cases beyond three years but within ten years, yet the sanction was granted by the Commissioner after the relevant assessment year had expired, the form was unsigned, and no contemporaneous clarification or correction was recorded by the approving authority. In the absence of any recorded exclusion of time under the fifth proviso to Section 149, the jurisdictional basis for the Section 148A(d) order and Section 148 notice was not sustained, and the reassessment action was quashed.</description>
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    <pubDate>Wed, 24 Apr 2024 00:00:00 +0530</pubDate>
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      <title>2024 (4) TMI 1319 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=464281</link>
      <description>Approval under Section 151 was found invalid where reassessment proceedings were initiated beyond the period prescribed in Section 149(1)(b). The approval form referred to Section 149(1)(b) for cases beyond three years but within ten years, yet the sanction was granted by the Commissioner after the relevant assessment year had expired, the form was unsigned, and no contemporaneous clarification or correction was recorded by the approving authority. In the absence of any recorded exclusion of time under the fifth proviso to Section 149, the jurisdictional basis for the Section 148A(d) order and Section 148 notice was not sustained, and the reassessment action was quashed.</description>
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