ITAT Quashes Reassessment: Approval from PCIT Instead of PCCIT Proves Fatal

Manju Jain Vs ITO (ITAT Delhi) ITAT Quashes Reassessment: Approval from PCIT Instead of PCCIT Proves Fatal The Delhi ITAT quashed the reassessment proceedings holding that a notice issued under Section 148 after the expiry of three years is invalid if the mandatory approval prescribed under Section 151 is not obtained from the correct authority. In the case, the original notice under the old reassessment regime was issued beyond the three-year period. Thereafter, proceedings were initiated under the new regime through Sections 148A(b) and 148A(d), followed by a fresh notice under Section 148. ...