Sanction u/s 151 is mandatory for issuing notice u/s 147

Sonu Khandelwal Vs ITO (ITAT Jaipur)

Section 150(1) provides exception to the limitation provided U/s 149 for issuing notice U/s 148.  Therefore, Section 150 of the Act can be pressed into service in a particular case of reopening based on the directions or giving effect to the order of the appellate authority only when the time limitation provided U/s 149 has already expired. In the case in hand, the time limit provided U/s 149 of the Act was certainly not expired as on 31

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