Notice u/s 148 After 3 Years Needs Pr.CCIT Approval – ITAT Says Sanction by Pr.CIT Invalid, Reopening Quashed

DCIT Vs Govinda Rajulu Srinivasan (ITAT Chennai)

Notice u/s 148 After 3 Years Needs Pr.CCIT Approval – ITAT Says Sanction by Pr.CIT Invalid, Reopening Quashed

Assessee ‘s case was reopened u/s 147 r.w.s. 144B by issuing notice u/s 148 dated 26.07.2022, resulting in addition of Rs.7 Crores u/s 68. Before CIT(A), Assessee challenged the validity of the notice itself, arguing that more than 3 years had elapsed from the end of AY 2017-18 & therefore approval of the higher authority i.e. Principal Chief Commissioner (Pr.CCIT) was mandatory u/s 151(ii). However, the notice

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