Approval for One Issue, Reopening for Another Is Legally Fatal

Kanubhai Ramdas Patel Vs ITO (ITAT Ahmedabad) Approval Says “Commodity Trading”, Reasons Say “LTCG”-Defective 151 Approval Dooms Penny-Stock Reopening-Unsigned / Mismatched Sanction u/s 151 Is Fatal Ahmedabad ITAT ‘SMC’ Bench in Kanubhai Ramdas Patel vs ITO (ITA No.1207/Ahd/2024, AY 2012-13, order dated 24-12-2025) allowed the assessee’s appeal and quashed the entire reassessment u/s 147 as void ab initio, holding that the mandatory approval u/s 151 suffered from fatal defects and total non-application of mind Assessee, a proprietor engaged in agricultural trading, had filed ROI...