ITAT Jaipur Quashes Time-Barred Reassessment for Lack of Proper Section 151 Sanction

RSD Containers Private Limited Vs ITO (ITAT Jaipur) The Jaipur Bench of the Income Tax Appellate Tribunal (ITAT) in RSD Containers Pvt. Ltd. vs. ITO (AY 2017-18, order dated 06 August 2025) quashed a reassessment notice and the consequent assessment order issued under Sections 147 and 148 of the Income Tax Act, 1961. The Tribunal held that the notice was issued beyond the permissible limitation period and without proper sanction from the specified authority as required under Section 151 of the Act, rendering the proceedings invalid in law. At the outset, the assessee’s counsel did not press ...