Reasons Must Precede Section 148 Notice, Reopening Quashed

Om Prakash Vs ITO (ITAT Delhi) Reasons First, Notice Later—ITAT Pulls Plug on Illegal Reopening-  148 Issued Before Satisfaction? Reassessment Non Est Delhi ITAT ‘SMC’ Bench in The Great Getsby Club of India Vs. ITO, Ward-2(3), New Delhi [ITA No. 7144/Del/2025, AY 2014-15, order dated 16.12.2025] allowed Assessee’s appeal and quashed reassessment proceedings where notice u/s 148 was issued prior to recording reasons and obtaining statutory approval. Tribunal noted that notice u/s 148 was issued on 19.01.2016, whereas reasons were recorded and approval of JCIT was obtained only on 17.0...