Section 148 Notice Invalid as PCIT Approval Failed After 3-Year Limit

Govintharaj Balakrishnan Vs ITO (ITAT Chennai) PCIT Approval Not Enough After 3 Years: Section 151 Is Not Empty Formality: Jurisdictional Lapse Fatal In Govintharaj Balakrishnan Vs. ITO, Ward-1, Virudhunagar, ITA No.2780/Chny/2025, AY 2018-19, order dated 31.12.2025, Chennai ITAT allowed Assessee’s appeal & quashed reassessment proceedings on jurisdictional ground. Assessee had originally filed return declaring salary income of ₹1.92 lakh. AO reopened assessment on account of alleged unexplained cash deposits of ₹51.63 lakh in a cooperative bank & completed reassessment u/s 147 r...