Reopening Beyond 3 Years Invalid Without Pr.CCIT Sanction: ITAT Kolkata

Nirmalkunj Sales Ltd. Vs DCIT (ITAT Kolkata) ITAT Kolkata Quashes Reopening – Notice u/s 148 Void Without Proper Sanction from Pr.CCIT Assessee challenged reassessment order passed pursuant to notice u/s 148 dated 30.07.2022. The notice mentioned prior approval of Pr.CIT-2, Kolkata obtained on 28.07.2022. Based on reassessment, AO made addition of ₹79,00,000 treating cash consideration received from sale of shares as unexplained cash credit. CIT(A) upheld reassessment & addition. Before Tribunal, Assessee argued that reopening was after three years from end of AY 2016-17, hence mandato...