Bombay HC Quashes Reassessment Notices as Sanction Was Obtained Under Wrong Provision

Zentest Software Private Limited Vs ACIT (Bombay High Court) The Bombay High Court held that reassessment proceedings initiated after obtaining sanction under Section 151(i) instead of the applicable Section 151(ii) of the Income Tax Act are invalid. Referring to its earlier decision in Siemens Financial Services Private Limited v. Deputy Commissioner of Income Tax, the Court observed that for Assessment Years 2016-17 and 2017-18, sanction ought to have been granted under Section 151(ii). Since the reassessment notices were based on an incorrect sanction, the notices were held to be invalid an...