Dismissing the petition the Court held that the Principal Commissioner, who applied his mind and granted approval in terms of requirement of law as provided in section 151 of the Income-tax Act, 1961. The remarks of the Joint Commissioner of Income-tax were not only to facilitate the Principal Commissioner to apply his mind. Writ petition dismissed.
Mahendra Sisodia v. ITO (2025) 483 ITR 314 (Raj)(HC)
S. 151 : Reassessment-Sanction for issue of notice –Approval taken of Principal Commissioner-Note sheets disclosing records placed containing remark of Joint Commissioner-Not resulting in wrongful exercise of jurisdiction by Principal Commissioner Remark of Joint Commissioner facilitating application of mind by Principal Commissioner-Sanction is valid. [S. 147, 148, Art. 226]
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