TOLA extension Do Not Alter Specified Authority under Section 151: Delhi HC

Bhagwan Sahai Sharma Vs DCIT (Delhi High Court) Delhi High Court has set aside a reassessment notice issued under Section 148 of the Income Tax Act, 1961, to Bhagwan Sahai Sharma for the Assessment Year (AY) 2017-18. The court’s decision hinges on the fundamental procedural requirement that such notices, especially when issued beyond a certain timeframe, must receive prior approval from a specifically designated higher authority, a condition found to be unfulfilled in this case. The petitioner, a 72-year-old senior citizen, had challenged the notice dated July 29, 2022. This notice was p...