Section 148 Notice Invalid Without PCIT/PCDG Sanction After 3 Years

Venkata Prasad Pulipati Vs ITO (ITAT Visakhapatnam) Wrong Boss Signed, Reopening Dies: ITAT Quashes 148 for Want of PCIT/PCDG Sanction The Visakhapatnam Bench of the ITAT quashed the reassessment framed u/s 147 r.w.s. 144B for AY 2016-17 on the ground of lack of valid sanction u/s 151. The notice u/s 148 dated 27-07-2022 was issued beyond three years from the end of the relevant AY. As per Section 151(ii) (post-Finance Act, 2021), such reopening mandatorily requires approval of the Principal Chief Commissioner / Principal Director General (or CCIT/DG). In the present case, the approval was obt...