Kavita Raneja v. ITO (2024) 232 TTJ 129 (UO) (Jodhpur) (Trib)

S. 151 : Reassessment-Sanction for issue of notice-Notice was issued before the expiry of four years from the end of the relevant assessment year-It should have been issued after obtaining the satisfaction of Jt. CIT-The approval obtained from the Principal CIT is not valid. [S. 147, 148, 151(ii)]

Held that the  return of income with the ITO, Ward-3(4), the notice under s. 148 issued by the said AO was valid notwithstanding that subsequently, the case of the assessee was transferred from the ITO, Ward-3(4), to ITO, Ward-3(1). However   the notice under S. 148 was issued before the expiry of four years from the end of the relevant assessment year, it should have been issued after obtaining the satisfaction of Jt. CIT and, therefore, the approval obtained from the Principal CIT is not valid. (AY. 2015-16)

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