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    <title>2023 (7) TMI 1628 - CALCUTTA HIGH COURT</title>
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    <description>The dominant issue was whether reassessment initiation was time-barred and, consequentially, which &quot;Specified Authority&quot; was competent to approve the order under s.148A(d) within the normal three-year period. The HC held that, after applying the fifth and sixth provisos to s.149(1) and excluding the time afforded to respond to the s.148A(b) notice plus seven additional days, the s.148A(d) order fell within three years. As the matter was within the three-year regime, approval by the Principal CIT (not the Principal Chief CIT) was legally required; the AO&#039;s approval from the Principal CIT was valid. The writ petition was dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=465589</link>
      <description>The dominant issue was whether reassessment initiation was time-barred and, consequentially, which &quot;Specified Authority&quot; was competent to approve the order under s.148A(d) within the normal three-year period. The HC held that, after applying the fifth and sixth provisos to s.149(1) and excluding the time afforded to respond to the s.148A(b) notice plus seven additional days, the s.148A(d) order fell within three years. As the matter was within the three-year regime, approval by the Principal CIT (not the Principal Chief CIT) was legally required; the AO&#039;s approval from the Principal CIT was valid. The writ petition was dismissed.</description>
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