Notice Invalid as Approval Under Section 151(ii) Was Defective: ITAT Raipur

Kamlesh Kukreja Vs ITO (ITAT Raipur) ITAT Raipur Quashes Reassessment for AY 2016-17 Due to Invalid Sanction u/s 151(ii); PCIT Not Competent Authority Beyond 3 Years The Raipur Bench of the ITAT, in Kamlesh Kukreja (Prop. Anmol Industries) vs. ITO  [ITA No.119/RPR/2025, AY 2016-17, order dt. 01-01-2026], first condoned a delay of 156 days in filing the appeal, holding that procedural delays should not defeat substantial justice, relying on Collector, Land Acquisition vs. Mst. Katiji (SC) and Inder Singh vs. State of MP (SC). On merits of jurisdiction, the Tribunal noted that reassessment proc...