Reopening Beyond 3 Years: ITAT Quashes 148 Notice Approved by Wrong Authority

Jag Preet Singh Narang Vs ITO (ITAT Delhi) Case was reopened for AY 2017-18 by notice u/s 148 dated 22.07.2022, i.e., beyond three years from end of AY. As per law applicable for that period, sanction for such reopening had to be obtained from Principal CCIT/Principal DGIT/CCIT/DGIT. AO, however, obtained approval only from PCIT, as admitted in para 3 of the notice itself. Assessee argued that such approval is incompetent & reopening is void-ab-initio, relying on Delhi HC ruling in Manish Gyanchand Mehta 173 taxmann.com 953. Tribunal held that since sanction was taken from an authority not...