Reassessment Quashed: Approval for Notice Beyond 3 Years Must Be PCCIT, Not PCIT

Wudstay Travels Private Limited Vs ACIT (ITAT Delhi) Delhi ITAT quashed reassessment u/s 147/148, holding that approval beyond 3 years must come from Principal Chief Commissioner or Principal Director General, not from a mere Principal Commissioner. Assessee had not filed return for A.Y. 2017-18. Based on information about time deposits & interest income, AO issued notice u/s 148A(b) on 01-06-2022 and framed assessment adding ₹3.10 crore u/s 69 along with minor additions. ITAT noted that the sanction for reopening was obtained only from the Principal Commissioner, though notice was issue...