Reopening Notice Quashed for Lack of Proper Sanction Under Section 151

Sonu Agarwal Vs ITO (ITAT Jaipur)

The assessee challenged the reassessment proceedings on the technical ground that the notice issued under Section 148 of the Income Tax Act, 1961, was invalid because it lacked proper sanction from the competent authority under Section 151 of the amended regime. Although this ground had been raised before the CIT(A), no finding was recorded. The Tribunal therefore examined the issue.

The assessee argued that both the order under Section 148A(d) and the notice under Section 148 were issued without approval from the authority mandated under Se

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