ITAT Mumbai Quashes Reopening Beyond 3 Years for Sanction by Wrong Authority

Paresh Hiralal Shah Vs ITO (ITAT Mumbai)

The appeal was filed by the assessee against the order dated 20.06.2025 passed by the National Faceless Appeal Centre (NFAC)/Commissioner of Income Tax (Appeals) under section 250 of the Income Tax Act, 1961 for Assessment Year (AY) 2018–19.

In this case, a notice under section 148A(d) of the Act was issued within three years from the end of the relevant assessment year. However, it was an admitted position that the notice under section 148 of the Act was issued after the expiry of three years from the end of the relevant assessment

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