Reopening Beyond Three Years Invalid Without PCCIT Approval: ITAT Amritsar

Imran Majeed Vs ITO (ITAT Amritsar) The Income Tax Appellate Tribunal adjudicated two appeals for Assessment Years (AY) 2018–19 and 2019–20 arising from reassessment orders passed under section 147 read with sections 144 and 148 of the Income-tax Act, 1961. For AY 2018–19, the assessee challenged the reassessment primarily on jurisdictional grounds, contending that the mandatory sanction under section 151(ii) was invalid. The Tribunal admitted an additional legal ground, noting that more than three years had elapsed from the end of the relevant assessment year and, therefore, approval fo...