Reassessment Without Proper Sanction – ITAT Delhi Quashes Notice u/s 148

Durga Agencies Pvt. Ltd. Vs ITO (ITAT Delhi) Delhi Tribunal quashed reassessment proceedings initiated against Assessee for AY 2017-18, holding that the mandatory approval required u/s 151(ii) was not obtained from the Principal Chief Commissioner of Income Tax. The defect was found to be jurisdictional, rendering the reassessment void. Assessee challenged the validity of notice u/s 148 dated 29.07.2022 issued by ITO. The notice was issued beyond three years from the end of the relevant assessment year, i.e., AY 2017-18. In such cases, approval of Principal Chief Commissioner or equivalent aut...