Reopening Quashed – Sec 151 Approval by PCIT Invalid Beyond 3 Years; Reassessment Void – ITAT Mumbai

DCIT Vs SPR Associates (ITAT Mumbai) Reopening Quashed – Approval by PCIT Instead of PCCIT Invalid Beyond 3 Years U/s 151 – Entire Reassessment Held Void – ITAT Mumbai Assessee challenged validity of reassessment notice issued under new regime u/s 148A/148 on ground that sanction u/s 151 was obtained from PCIT though notice was issued beyond 3 years, where approval of PCCIT/CCIT level authority was mandatory. Revenue contested on merits relating to dividend vs capital receipt issue; however Tribunal first examined jurisdictional validity. ITAT held that under new regime, where m...