ITAT Delhi Quashes Section 147 and 148 Proceedings Over Improper Section 151 Sanction

Advertisement Guljar Vs ITO (TDS) (ITAT Delhi) Approval First, Reasons Later? ITAT Delhi Strikes Down Entire 147 Proceedings-148 Notice Void for Pre-Dated Sanction In this appeal, Guljar challenged the reassessment framed u/s 147/148 on the ground that the AO recorded reasons for reopening after obtaining sanction u/s 151, rendering the approval invalid in the eyes of law. The AO recorded reasons on 30.03.2016, stating that cash deposits of ₹55,12,000 had escaped assessment. However, the sanction from PCIT was granted two days earlier, on 28.03.2016– prior to the formation of the re...