Reassessment Void: Notice Against Non-Resident Invalid Due to Lack of Approval and Time-Barred Issuance Under Tax Law.

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....The reassessment proceedings were initiated against a non-resident individual deriving income from other sources after three years had elapsed. The sanction of the Specified Authority was not obtained as per the prevalent law. Information was received regarding possible infringement of section 56(2)(vii) related to transactions of immovable property. The Tribunal held that the sanction of the Specified Authority was mandatory and not obtained in conformity with the law. Additionally, the notice u/s 148 was time-barred as per section 149 since it was issued after three years, and the amount alleged to have escaped assessment was less than Rs. 50 lakh. Consequently, the notice issued u/s 148 was void ab initio and bad in law, and the decision was in favor of the assessee.....