Chennai ITAT Quashes Reassessment – Notice u/s 148 Beyond 3 Years Needs PCCIT Approval, Not PCIT Approval

Sri Sundari Enterprises Vs ITO (ITAT Chennai) The Chennai ITAT quashed the reassessment proceedings for AY 2018-19 holding that a notice issued u/s 148 beyond three years from the end of the assessment year is invalid if approval is obtained only from the PCIT instead of the PCCIT as mandated u/s 151(ii). The Tribunal admitted the assessee’s additional legal ground following NTPC Ltd. and held that the issue went to the very root of jurisdiction. In the present case, although notice u/s 148A(b) was issued within three years, the final notice u/s 148 was issued on 06.04.2022 after expiry of ...