S. 151 : Reassessment – Sanction for issue of notice–Issuance of Notice requires the sanction of PCIT where the Notice is issued after 4 years – Relaxation Act not a bar for appropriate sanction- Reassessment notice is held to be bad in law. [S. 147, 148, Art, 226]

It has been held that where the Notice issued on March 31, 2021, beyond 4 years, is with the approval of JCIT considering the Relaxation Act, the same should be issued with the sanction of the PCIT or CIT. (W.P.(C) No. 20919 of 2021 dated January 24, 2022 & Ors. W.P.(C) No.20919 of 2021 dated January 24, 2022)

Ambika Iron and Steel Pvt. Ltd v. PCIT (Orissa)(HC)

[CORAM : THE CHIEF JUSTICE S. MISHRA]