Jurisdiction Failed: ITAT Voids Section 148 Notice Due to Wrong Authority Approval

Siddharth Raikumar Nahar Vs DCIT (ITAT Pune)

Mandatory Approval Violation: ITAT Quashes Reassessment Beyond 3 Years; 2. Reassessment Sanction Error: ITAT Rules PCIT Cannot Approve Beyond Three Years; Reassessment Quashed for Invalid Approval – ITAT Pune Rules Section 151 Violation Renders Notice Void

Assessee challenged reopening of assessment u/s 147, contending that the approval u/s 151 for issue of notice u/s 148/148A(d) was invalid, as it was granted by the Principal Commissioner (PCIT) instead of the Principal Chief Commissioner (PC

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