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Income Tax

Section 151(ii) Violation Invalidates Late Section 148 Notices

Case Law Details

Case Name
Hisar Leading Bank Co-op Non-Agri Thrift & Credit Society Vs ITO (ITAT Delhi)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2016-17
Advertisement Hisar Leading Bank Co-op Non-Agri Thrift & Credit Society Vs ITO (ITAT Delhi) CIT Sanction After 3 Years Is Fatal: Wrong Authority’s Approval u/s 151(ii) Kills 148 Notices for AYs 2016-17 & 2017-18-  Ashish Aggarwal Can’t Cure Wrong Sanction: ITAT Delhi Strikes Down Reopening Delhi ITAT ‘E’ Bench in The Hisar Leading Bank Co-op Non-Agri Thrift & Credit Society vs ITO, Ward-I, Hisar (ITA Nos. 5113 & 5114/Del/2025, AYs 2016-17 & 2017-18, order dated 24-12-2025) quashed the reassessment proceedings in entirety, holding that notices u/s 148 issued on ...
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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 5,926

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1 Comment
  1. After Notification dated 29 March 2022 if appropriate authority issue sanction us 151 in favor of JAO is invalid, since according to sec 151A it is mandatory for the A. O. authorities concerned to initiate proceedings pertaining to re-assessment under Section 148A and 148 of the Act in a faceless manner, (rather than being proceeded by the local jurisdictional officer)

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