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ORDER 1. The petitioner has called into question a notice for re-assessment issued for Assessment Year 1998-99 by the Assessing Officer, the second respondent, on 29 March 2005. The petitioner has also called into question an order passed by the Assessing Officer on 10 June 2014 disposing of the objections to re-opening of the assessment. 2. The petitioner filed its return of income for A.Y. 1998-99 on 30 November 1998. The petitioner was assessed on 22 March 2000 under Section 143(3) of the Income Tax Act, 1961 the Act by the Assessing Officer. The petitioner received a notice dated 29 March 2005 under Section 148. The petitioner filed writ proceedings Writ Tax No.492 of 2006 before this Court challenging the re-assessment notice which petition was finally disposed of on 23 April 2014 by remanding the proceedings back to the Assessing Officer to dispose of the objections of the petitioner to re-opening of the assessment. The Assessing Officer disposed of the objections, rejecting them, by an order dated 10 June 2014. 3. The submission which has been urged on behalf of the petitioner is that in the present case, the assessment was sought to be re-opened beyond the period of four years of the end of the relevant assessment year and since the original order of assessment was made under Section 143(3), no notice could have been issued without the sanction of the Chief Commissioner or the Commissioner. It has been urged that as a matter of fact, no sanction had been issued. 4. While disposing of the objections of the petitioner, the Assessing Officer dealt with the objection to the effect that no sanction was obtained of the Commissioner under Section 151 in the following observations : ",,..In certain cases the AO has to be of a particular rank and satisfaction or approval of the higher authority is required. It needs to be emphasized that as per the Act satisfaction required before issuance of notice for reassessment/assessment of the AO and not of any higher authority whose approval may be required. Such approval is an internal administrative process for better regulation of the Machinery of the tax collection. The manner in which the assessee has set out the…

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