ITAT Mumbai: Reopening Invalid Without Proper Sanction-Entire Assessment Quashed

ITO Vs Vinod Bhanji Shah (ITAT Mumbai) The Mumbai ITAT quashed reassessment proceedings on the ground that mandatory approval under Section 151 was obtained from the wrong authority, rendering the notice issued under Section 148 invalid. The Tribunal observed that since more than three years had elapsed from the end of the relevant assessment year (AY 2017–18), approval ought to have been obtained from the higher authority (PCIT/CCIT level as prescribed under Section 151(ii)). However, in the present case, approval was taken from an incorrect authority, which is a jurisdictional defect. Rely...