Section 148 Notice Quashed as Approval Was Obtained From Wrong Authority

Sudhir Motiram Patil Vs ITO (ITAT Mumbai) The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) allowed the assessee’s appeal for Assessment Year 2017-18 and quashed the reassessment proceedings initiated under Sections 147 and 148 of the Income Tax Act. The Tribunal held that the notice issued under Section 148 was invalid due to lack of approval from the competent specified authority and was also barred by limitation. The assessee had challenged the reopening of assessment, validity of notice under Section 148, sanction under Section 151, addition under Section 69A relating to cash ...