Notice issued u/s 148 was invalid due to non-compliance of section 151

Arnab Kumar Goswami Vs ITO (ITAT Kolkata)

Conclusion: AO failed to obtain requisite approval from PCCIT under section 151 for issuance of reassessment notice under section 148 beyond 3 years, the proceedings were deemed to be non-compliance to the statutory requirement under the law and the consequent additions made by AO were also not justified.

Held: Assessee, declared an income of Rs. 3,52,310/- for the assessment year. He purchased a property at Rajarhat for Rs. 25,00,000/-, while the stamp duty value was Rs. 35,36,655/-. The difference

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