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Reassessment Falls on Threshold Error: Authority Lacked Power
Case Law Details
- Case Name
- Toyota Boshoku Corporation Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Delhi
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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...
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