Reassessment proceedings beyond 3 years invalid if sanction by lower authority. Order & notice quashed, following Siemens case.

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....Sanction by Principal Commissioner of Income Tax instead of Principal Chief Commissioner of Income Tax u/s 151(ii) for reassessment proceedings beyond three years from end of assessment year is invalid. Consequent order u/s 148A(d) and notice u/s 148 are quashed and set aside. Decided in favor of assessee, following Siemens Financial Services Private Limited case.....