Reopening Beyond 3 Years Invalid for Income Below ₹50L – Wrong Sec 151 Sanction Voids Reassessment – ITAT Mumbai

DCIT Vs Pranavkumar Prafulchandra Vora (ITAT Mumbai) Reopening Beyond 3 Years Invalid Where Escaped Income & lt; ₹50 Lakh – Wrong Sanction u/s 151 Vitiates Reassessment – ITAT Mumbai The Tribunal adjudicated cross appeals relating to alleged penny stock transactions where the AO reopened assessment and made addition u/s 68 alleging accommodation entries in the scrip of Alankit Ltd. However, the assessee challenged jurisdiction through cross-objection, contending that notice u/s 148 issued under the new regime dated 28.07.2022 was beyond three years and sanctioned by an incorrect auth...