Jurisdictional Misfire -Wrong Sanction Sinks Reopening: PCIT Approval Not Enough Beyond 3 Years

DCIT Vs Sameep Fabrics Pvt. Ltd. (ITAT Ahmedabad)

Revenue appealed against deletion of addition on alleged accommodation-entry purchases, while Assessee filed cross-objections challenging the very jurisdiction of reopening. Tribunal noted that notices u/s 148 for both AYs 2017-18 & 2018-19 were issued beyond three years & approvals were granted only by PCIT. As per section 151(ii), when more than three years have elapsed, sanction must be from Principal Chief Commissioner or Chief Commissioner, and

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