ITAT Quashes Reassessment After 3 Years for Invalid Sanction

Ratan N. Motwani (HUF) Vs ITO (ITAT Mumbai) ITAT Mumbai Quashes Reassessment for Want of Proper Sanction; PCIT’s Approval Invalid When Notice Issued After 3 Years Assessee–HUF appealed against reassessment u/s 147 where the AO made additions of ₹51,90,400 & ₹51,89,440 towards alleged accommodation-entry sales to Abhinandan Diamond Pvt Ltd & Aisshpra Gems/Gravit Diamonds Pvt Ltd, & ₹22,00,000 as unexplained loan repayment. Along with merits, Assessee raised strong legal grounds against reopening—primarily invalid sanction u/s 151, lack of jurisdiction, & limitation u...