ITAT Mumbai Quashes Reopening: Approval by Wrong Authority u/s 151 Makes Entire Reassessment Void

Mita Vora Vs ITO (ITAT Mumbai) ITAT Mumbai Quashes Reopening: Approval by Wrong Authority u/s 151 Makes Entire Reassessment Void In a decisive ruling, the ITAT Mumbai held that reassessment proceedings are invalid if approval under Section 151 is obtained from the wrong authority, and accordingly quashed the entire reassessment. The case involved reopening beyond 3 years from the end of the assessment year, where law mandates approval from Principal Chief Commissioner (PCCIT). However, approval was taken from Principal Commissioner (PCIT). The Tribunal held: Sanction under Section 151 is a ju...