2012 (11) TMI 860

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....d this appeal against the order of income tax appellate Tribunal for the following question of law. Whether, on the facts and in the circumstances of the case, the Tribunal is legally correct in holding the notice under section 148 of the Act and the consequent assessment proceedings as invalid for want of proper sanction of the Authority mentioned in the provisions of section 151 of the Act, tho....

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....the proviso contained in Section 151 of the Act, we find that proviso clearly stipulates that after expiry of four years from the end of the relevant assessment year, no notice under Sub Section 1 shall be issued unless the Chief Commissioner or the Commissioner is satisfied on the reasons supported by the assessing officer that it is a fit case for issuance of notice. Referring to the word 'afor....