https://www.taxtmi.com/caselaws?id=466029 Challenge to validity of reopening where sanction for issuing notice referenced an omitted statutory provision resulted in finding that the sanction was mechanical and lacked due application of mind. The text clarifies that reliance on a non-existent provision in the sanction form renders the sanction invalid and vitiates subsequent proceedings; consequently, the reassessment and the consequential revision under administrative review were quashed. The note emphasizes the requirement that sanctioning authority must correctly identify applicable legal provisions and exercise independent judgment for a valid reopening. en-us Fri, 12 Sep 2025 00:00:00 +0530 Mon, 19 Jan 2026 14:14:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466029 Challenge to validity of reopening where sanction for issuing notice referenced an omitted statutory provision resulted in finding that the sanction was mechanical and lacked due application of mind. The text clarifies that reliance on a non-existent provision in the sanction form renders the sanction invalid and vitiates subsequent proceedings; consequently, the reassessment and the consequential revision under administrative review were quashed. The note emphasizes the requirement that sanctioning authority must correctly identify applicable legal provisions and exercise independent judgment for a valid reopening. Case-Laws Income Tax Fri, 12 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466029