ITA No.1001/Chny/2022 (AY 2014-15)

Parties Involved

Facts Summary

The assessee, Mr. Krishnan Vidya Shankar, filed his original return of income for the Assessment Year 2014-15 declaring total income of Rs.1,95,62,940/- on 27.11.2014. The Assessing Officer (AO) issued a notice under section 148 of the Income Tax Act, 1961 on 24.03.2020 for the year under consideration. The assessee challenged the jurisdiction of the AO to have re-opened the assessment, arguing that the notice was issued after four years from the end of the relevant Assessment Year, which required necessary sanction under section 151 of the Act. The assessee contended that the Commissioner did not apply his mind while granting the sanction, which was merely an endorsement of 'Yes' without proper reasoning.…

Legal Issues

• 1. Whether the sanction granted by the Principal Chief Commissioner of Income Tax (Appeals) for re-opening of assessment was valid in law?

Judgment Outcome

Decided in favour of Assessee.

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