https://www.taxtmi.com/caselaws?id=780578 HC held the reopening notice under s.148 invalid for lack of competent sanction under s.151(2). Although the notice was issued beyond four years, TOLA's deeming provision brought it within time, so approval had to be by the authority specified in s.151(2); the PCIT's approval was not the proper sanction for a notice deemed within four years. The court found the record showed only a recommendation by the Jt. Commissioner and not requisite approval, depriving the issuing officer of jurisdiction. Appeal allowed. en-us Mon, 06 Oct 2025 00:00:00 +0530 Sat, 01 Nov 2025 08:17:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780578 HC held the reopening notice under s.148 invalid for lack of competent sanction under s.151(2). Although the notice was issued beyond four years, TOLA's deeming provision brought it within time, so approval had to be by the authority specified in s.151(2); the PCIT's approval was not the proper sanction for a notice deemed within four years. The court found the record showed only a recommendation by the Jt. Commissioner and not requisite approval, depriving the issuing officer of jurisdiction. Appeal allowed. Case-Laws Income Tax Mon, 06 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780578