Dismissing the SLP the Court held that Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner as required under section 151 of the Act for reopening the assessment after four years, and that the satisfaction of the Additional Commissioner did not give jurisdiction. (AY 2015-16)
ITO v. Rinku R. Rai (2023) 454 ITR 35/ 293 Taxman 689 (SC) Editorial : Rinku R. Rai v. ITO (2023) 454 ITR 33(Bom)(HC)
S. 151 : Reassessment-Sanction for issue of notice-After the expiry of four years-Sanction of Additional Commissioner-Notice Not Valid-SLP dismissed.[S.144B (1)(xvi), 147, 148, Art. 131]