Notice u/s 148 Invalid Due to Lack of Proper Sanction by Joint Commissioner, Violating Section 151 Requirements.

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....Reopening of assessment u/s 147 - There is complete non application of mind on the part of Joint CIT, Range 5(3), Mumbai, while granting sanction under section 151 of Act. There is no prior sanction granted by Respondent No.2 before issuance of notice under Section 148 of the Act. Therefore, the jurisdictional condition of complying with Section 151 was not satisfied - HC....