Sanction from Joint Commission for reopening of assessment beyond four years is bad in law

Smt. Sonal D. Mehta Vs ITO (ITAT Ahmedabad) ITAT Ahmedabad held that as per provisions of section 151(1) of the Income Tax Act reopening of assessment beyond four years period needs sanction from either Principal Chief Commissioner/ Chief Commissioner/ Principal Commissioner or Commissioner. However, sanction from Joint Commissioner in the present case makes the entire reopening proceedings bad in law. Facts- The assessee claimed LTCG on sale of various shares at conventional rate of tax @10%. In the subsequent A.Y. 2006-07, the same pattern was adopted by the assessee however, the Revenue tre...