ITAT Quashes Section 148 Notice Beyond 3 Years for Wrong Section 151 Approval

Praveen Kumar Diddige Vs ITO (ITAT Hyderabad) Reassessment Quashed: ITAT Hyderabad Holds Sec.148 Notice Invalid for Want of Proper Sec.151 Sanction Beyond 3 Years In this appeal, Praveen Kumar Diddige challenged the validity of the reassessment initiated by the AO for AY 2017-18 through a notice issued u/s 148 dated 30.06.2022. Assessee contended that the said notice was issued beyond three years from the end of the relevant assessment year, thereby attracting the amended provision of sec.151(ii), which mandates that the Competent Authority to grant approval must be the Principal Chief Commiss...