Held that when the reopening is done after expiry of four years from end of assessment year and original assessment was completed under section 143(3), then irrespective of rank of Assessing Officer who has reopened assessment, it is mandatory condition that satisfaction of Pr. CCIT/CCIT/PCIT/CIT is required. Followed Reliable Finhold Ltd v. UOI (2014) 369 ITR 419 (All.)(HC). (AY. 2007-08)
Aries Marketers (P.) Ltd. v. CIT (2021) 188 ITD 671 / 212 TTJ 930 / 204 DTR 233 (SMC) (All.)(Trib.)
S. 151 : Reassessment-Sanction for issue of notice-After the expiry of four years-It is mandatory that satisfaction of Pr. CIT / CCIT / PCIT / CIT. [S. 143(3), 147, 148]