Reopening U/s. 148 without approval of designated authority is void ab initio

DCIT Vs Bhaijee Portfolio Pvt. Ltd. (ITAT Delhi) In this From the records, it can be clearly seen that the notice has been issued prior to the approval. Thus, reopening u/s 148 is without the approval of the designated authority and as such reassessment itself is bad and without any jurisdiction. The mandatory conditions of Section 148 has not at all followed by Revenue. Therefore, the re-opening itself is void ab initio and does not survive. FULL TEXT OF THE ITAT JUDGMENT The appeal is filed by the Revenue and the Cross Objection is filed by the assessee against the order dated 29/05/2015 pas...