In the appeal the revenue urged that the assessment was completed u/s 143(1) and notices for reassessment was issued within four years period the sanction was required. Appellate Tribunal  allowed the appeal on the ground that the sanction was obtained of the CIT, instead of JCIT hence the reassessment was quashed.  Dismissing the appeal of the revenue the Court held that since the foundational facts sought to be urged in the present appeals are diametrically opposite to the case, the appeal is not maintainable. (AY. 2006-07)