Reopening Beyond Three Years Without Sanction Void ab Initio: ITAT Mumbai

Niraj Sarju Mandal Vs DCIT (ITAT Mumbai) In the case of Niraj Sarju Mandal vs. DCIT, the Income Tax Appellate Tribunal (ITAT) of Mumbai quashed a reassessment proceeding for the Assessment Year (AY) 2016-17, ruling that the notice was invalid because it lacked proper sanction from the correct authority. The core issue before the ITAT was the validity of a notice issued under Section 148 of the Income Tax Act, 1961, which was used to reopen the petitioner’s case. This notice was issued on June 30, 2022, well beyond the standard three-year period from the end of the relevant assessment ye...