It has been held that where the Notice issued on March 31, 2021, beyond 4 years, is with the approval of JCIT considering the Relaxation Act, the same should be issued with the sanction of the PCIT or CIT. ( W.P.(C) No.20919 of 2021 dated January 24, 2022& Ors W.P.(C) No.20919 of 2021 dated January 24, 2022 )
Ambika Iron and Steel Pvt. Ltd v. PCIT( 2022) 326 CTR 871 /213 DTR 446 /(2023)452 ITR 285 (Orissa ) (HC) www.itatonline/org
S. 151 : Reassessment – Sanction for issue of notice – Issuance of Notice requires the sanction of PCIT where the Notice is issued after 4 years – Relaxation Act not a bar for appropriate sanction- Reassessment notice is held to be bad in law . [ S. 147, 148 , Art , 226 ]