Since assessment made u/s 143(3), no notice can be issued without satisfaction of CCIT/CIT – S. 151(1)

Sub-section (1) of Section 151 provides inter alia that where an assessment has been made under section 143(3), a notice under section 148 cannot be issued by an Assessing Officer, who is below the rank of Assistant Commissioner or Deputy Commissioner unless the Joint Commissioner is satisfied on the reasons recorded by the Assessing Officer that there is a fit case for the issuance of a notice. The proviso to sub-section (1), however, requires the satisfaction of the Chief Commissioner/ Commissioner after the expiry of a period of four years from the end of the

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