Approval from PCIT Instead of PCCIT Invalidates Section 148 Notice: ITAT Pune

Hareshkumar Dungarmal Jain Vs DCIT (ITAT Pune)

Income Tax Appellate Tribunal (ITAT) Pune Bench heard two appeals filed by assessees, including Hareshkumar Dungarmal Jain, against separate orders dated 3 August 2024 passed by the Commissioner of Income Tax (Appeals) / NFAC, Delhi, for Assessment Year (AY) 2018–19. Since both cases involved identical issues, they were disposed of through a common order, with ITA No. 1933/PUN/2024 taken as the lead case.

Facts of the Case
The assessee filed his return of income on 26 September 2018, declaring a

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