Re-assessment beyond 4 years without recording satisfaction of CIT is invalid

Advertisement ACIT Vs ECI Engineering & Construction Co. Ltd (ITAT Hyderabad) ITAT Hyderabad held that for re-assessment beyond a period of 4 years, recording of satisfaction by the CIT is a must under the Income Tax Act, 1961. In absence of the same, re-assessment proceedings are invalid. Facts- The assessee in the present case contends that the notice u/s 148 was issued without obtaining the satisfaction of the CIT-II, Hyderabad / CBDT. The contention of the assessee is that the notice was issued as if the re-opening was done within 4 years under clause (1) of section 147 of the Act. ...