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Reassessment Invalid: Joint Commissioner's Approval u/s 151 for Reopening Beyond Four Years Challenged for Lack of Authority.
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....Reopening of assessment u/s 147 - There is no indication of any application of mind by the authority. Moreover, the approval under Section 151 of the Act had to be granted by the Principal Chief Commissioner, or the Chief Commissioner, or the Principal Commissioner, or the Commissioner, if the reopening is beyond four years. However, the above approval in the instant case was issued by the Joint Commissioner and therefore, it was not a valid approval under Section 151 of the IT Act. - HC....