Section 148 notice without proper sanction U/s. 151(1) is invalid

Maruti Clean Coal & Power Ltd Vs. ACIT (Chhattisgarh High Court)

When we refer to Section 151(1) the proviso therein, specifically deals with the Chief Commissioner or the Commissioner to be satisfied on the reasons recorded by the Assessing officer for issuance of a notice after the expiry of 4 years from the end of the  relevant assessment year. It is this what is missing in the instant case. There can be no dispute as regards the requirement of Act to be strictly complied with. In the absence of the no

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