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

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 reasons themselves....