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Reopening Notice Invalid Without Proper Section u/s 151 – ITAT Quashes Reassessment
Case Law Details
- Case Name
- Ramachandran Meenakshi Vs ITO (ITAT Chennai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Chennai
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Ramachandran Meenakshi Vs ITO (ITAT Chennai)
Reopening Notice Invalid Without Proper Section u/s 151 – ITAT Quashes Reassessment
The assessee challenged the validity of reopening notice u/s 148 for AY 2018-19 on the ground that the mandatory sanction from the specified authority u/s 151 was not obtained. The AO had issued notice u/s 148A(b) on 23.03.2022 and notice u/s 148 on 05.04.2022, after obtaining approval only from the Principal Commissioner of Income Tax (PCIT).
The assessee contended that since more than three years had elapsed from the end of the relevant assessment year (31.03.202...
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