2025 (12) TMI 333

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....len Haokip, Sr.DR ORDER PER RAJESH KUMAR, AM : This is an appeal filed by the assessee against the order dated 28.12.2024, passed by the ld. CIT(A), National Faceless Appeal Centre, Delhi, for the assessment year 2016-2017. 2. The only issue raised by the ld. counsel of the assessee during the course of hearing was that the proceedings initiated u/s.148 of the Act is invalid as the cas....

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....al contentions and perusing the material available on record, we find that admittedly, the case of the assessee has been reopened after a period of three years from the end of the assessment year and, therefore, the sanction of ld. Pr.CCIT has to be obtained for issuing notice u/s.148 of the Act and not the ld. Pr.CIT whose approval was in fact obtained for issuance of notice. Therefore, the reope....