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Section 148 Notice Invalid as PCIT Approval Failed After 3-Year Limit
Case Law Details
- Case Name
- Govintharaj Balakrishnan Vs ITO (ITAT Chennai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Chennai
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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 reass...





