Agnello Oswin Dias v. ACIT
161 Taxmann.com 16High Court2024#6875 most cited
What is Agnello Oswin Dias v. ACIT authority for?
Sanction for reassessment proceedings initiated after three years from the end of the relevant assessment year must be obtained from the Principal Commissioner of Income Tax (PCCIT) under Section 151(ii). The proviso to Section 151, inserted w.e.f. 01.04.2023, does not apply retrospectively to proceedings initiated before that date.
16
judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2025 to 2026.
Also referred to as
Agnello Oswin Dias v. ACIT · Section 151 · Section 149 · reassessment · sanctioning authority · PCCIT · Principal Commissioner of Income Tax · retrospective effect · proviso to Section 151 · after 3 years