Reassessment Notice Invalid Due to Absence of PCCIT Approval Beyond Three Years

Javitri Devi Vs ITO (ITAT Delhi) In this case before the Income Tax Appellate Tribunal (ITAT), Delhi, the assessee challenged the validity of reassessment proceedings for Assessment Year 2016–17. The dispute centered on whether the notice issued under Section 148 of the Income-tax Act, 1961 was valid in law due to the nature of approval obtained under Section 151(ii). The reassessment process involved issuance of an initial notice under Section 148 on 25.04.2021, followed by notices under Section 148A(b) on various dates. An order under Section 148A(d) was passed on 26.07.2022, and a fresh n...