Sanction for issuing a reopening notice cannot be mechanical

Kalpana Shantilal Haria Vs. ACIT (Bombay High Court)

There can be no dispute with regard to the application of Section 292B of the Act to sustain a notice from being declared invalid merely on the ground of mistake in the notice. However, the issue here is not with regard to the mistake/ error committed by the Assessing Officer while taking a sanction from the Joint Commissioner of Income Tax but whether there was due application of mind by the Joint Commissioner of Income Tax while giving the necessary sancti

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