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The learned Commissioner of Income-tax (Appeals) grossly erred in not appreciating the facts and in the circumstances of the case and in law that the notice under section 148 has been issued beyond the period of four years from the relevant assessment year and is issued in violation of mandatory condition provided in section 151 of the Act.

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Section 120(4)(b), 147 & 148 of the Income Tax Act, 1961 —  Reassessment — Reassessment orders passed by Joint Commissioner void ab intio and liable to be quashed as no specific order was passed by Principal Chief Commissioner or Chief Commissioner or Principal Commissioner under section 120(4)(b) authorizing Joint Commissioner to act as an AO in case of assessee and there was no valid authority and jurisdiction to pass assessment orders — Kishore Vithaldas vs. Joint Commissioner of income tax [2019] 76 ITR (trib) 623 (Mumbai)

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