Assessment Reopening u/s 147 Challenged for Lack of Proper Sanction; Digital Signature Date Considered Valid.

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....Reopening of assessment u/s 147 - Whether no proper sanction/approval on the date of issuance of notice under Section 148 is concerned, provision under Section 151? - In view of specific provision under the Act of 1961, the document i.e. sanction/approval under Section 151 of the Act of 1961 issued by Competent Authority in case of petitioners will be deemed to be an authenticated document. In the 'Note' appended at the bottom of sanction/approval under Section 151 it is mentioned that “if digitally signed”, the date of signature may be taken as date of document. - HC....