Section 148 Notice Invalid Because PCCIT Approval Was Mandatory

Niraj Vs ITO (ITAT Delhi) Wrong Sanction Sinks Reassessment: Delhi ITAT Quashes 148 Notice Issued with PCIT Approval Instead of PCCIT Delhi ITAT, Delhi Bench ‘E’, in Niraj Vs ITO (ITA No.3308/Del/2025; AY 2018-19; order dated 19-12-2025), quashed the reassessment proceedings on the ground of invalid sanction u/s 151. The Tribunal noted that the notice u/s 148 dated 01-04-2022 was issued beyond three years from the end of the relevant AY and, therefore, mandatory prior approval of the Principal Chief Commissioner of Income Tax (PCCIT) was required under section 151(ii). However, the Assessi...