Reassessment Quashed for Sanction by Incompetent Authority

Suresh Kumar Giddaluru Vs Jurisdictional Assessing Officer (ITAT Surat) Reassessment Quashed for Invalid Sanction: Approval by PCIT Instead of Competent Authority Renders Notice Void The Surat Bench of the ITAT allowed the assessee’s appeal for AY 2018-19 by quashing the reassessment proceedings on a pure jurisdictional defect. The Tribunal held that since the notice under section 148 was issued on 05.04.2022—after expiry of three years from the end of the relevant assessment year—the mandatory sanction under section 151 was required to be granted by the Principal Chief Commissioner/Chie...