ITAT Chandigarh Quashes Reassessment Beyond 3 Years for Lack of Proper Section 151(ii) Sanction

Mandeep Kaur Vs ITO (ITAT Chandigarh) Introduction The Income Tax Appellate Tribunal (ITAT), in the case of Ms. Mandeep Kaur vs. ITO, has delivered a significant ruling reinforcing the principle that jurisdictional conditions under reassessment provisions are mandatory and cannot be diluted by administrative instructions. The Tribunal quashed reassessment proceedings initiated under Section 148 due to lack of approval from the statutorily prescribed authority, thereby providing important clarity on post-Finance Act 2021 reassessment procedures. This ruling assumes critical importance, particul...