ITAT Delhi Quashes Reopening for Invalid Section 151 Approval

ACIT Vs Pradeep Patil (ITAT Delhi) These consolidated appeals involved Revenue’s challenges against CIT(A)/NFAC orders for AYs 2017-18 & 2018-19, along with Assessee’s Cross-Objection challenging the very validity of reassessment proceedings. Assessee argued that the 148A(d) orders & subsequent 148 notices were void because the Assessing Officer wrongly obtained approval from the PCIT instead of the statutorily mandated Principal Chief Commissioner/Chief Commissioner/Principal DG/DG, as required u/s 151(ii) in cases where more than three years had elapsed from the end of the releva...