Section 147 of Income Tax Act, 1961— Re-opening of assessment— In the instant case, revenue has only urged the following question of law for our consideration:
“Whether on the facts and in circumstances of the case and in law, the Tribunal is correct in upholding the order of CIT(A) in quashing the assessment order passed in the proceedings u/s 147 read with section 143(3) of the Act”

Held that— This in view of the decision of this Court in Ghanshyam K. Khabrani v. Asst. CIT (2012) 346 ITR 443 (Bom) wherein, in identical circumstances, this Court held that where the Act provides for sanction by the Joint Commissioner of Income Tax in terms of section 151, then the sanction by the Commissioner of Income Tax would not meet the requirement of the Act and the reopening notice will be without jurisdiction.[PR. COMMISSIONER OF INCOME TAX, CENTRAL-2. VERSUS M/S. KHUSHBU INDUSTRIES.][2019] 19 ITCD Online (11) [BOMBAY HIGH COURT]