Reassessment Falls on Threshold Error: Authority Lacked Power

Toyota Boshoku Corporation Vs ACIT (ITAT Delhi) Wrong Authority’s Sanction Is Jurisdictional Suicide: PCIT Approval Not Enough Beyond 3 Years: Reassessment Set Aside for AYs 2016-17 & 2017-18 Delhi ITAT ‘D’ Bench in Toyota Boshoku Corporation vs ACIT, Circle-3(1)(1), New Delhi (ITA Nos.2462 & 2463/Del/2024, AYs 2016-17 & 2017-18, order dated 24-12-2025) quashed the entire reassessment proceedings, holding that approval for issuing notice u/s 148/148A(d) was obtained from an incompetent authority, striking at the very root of jurisdiction. The first notice u/s 148 was issued o...