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    <title>2026 (2) TMI 932 - ITAT DELHI</title>
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    <description>Reopening of assessment under the Income-tax Act was challenged on the ground that the statutory sanction for issuance of a section 148 notice was not obtained in the manner prescribed; the sanction was granted by officers other than those authorised by the statute. Applying the principle that a statutory sanction must be procured in the prescribed manner, the notice issued pursuant to the defective sanction and the assessment framed after reopening were held invalid. The defective sanction rendered the reopening and subsequent assessment unsustainable, and merit-based grounds were treated as academic following quashing of the assessment.</description>
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