Reopening Beyond 3 Years Quashed for Want of Proper Section 151(ii) Sanction from Pr. CCIT

Sheetal Clothing Company Pvt. Ltd. Vs DCIT (ITAT Mumbai) For AY 2017-18, the Assessing Officer issued notice under section 148 on 29.07.2022 after passing an order under section 148A(d) on the same date, alleging unexplained unsecured loans of about ₹72.97 lakh. This was clearly more than three years after the end of the assessment year (which ended on 31.03.2018, so the three-year period expired on 31.03.2021). Under the post-2021 reassessment regime, where notice is issued after three years and the alleged escaped income exceeds ₹50 lakh, prior sanction must be obtained from the higher a...