No digital/physical signatures of approving authority – Section 148 notice quashed

Rajesh Kumar Mishra Vs ITO (ITAT Delhi) The Delhi Bench of the ITAT decided the appeal of the individual against the order of CIT(A)/NFAC. The Assessing Officer had reopened assessment u/s 147 r.w.s. 144/144B and made the addition. The assessee challenged the reopening, arguing that no valid notice u/s 148A was issued and no proper sanction u/s 151 was obtained. On examining the approval u/s 151, the Tribunal found that it lacked signatures of the PCIT, and despite directions, the Revenue failed to produce a duly signed approval. Holding that the absence of valid sanction rendered the notice u...