Reassessment Beyond 3 Years Void for PCIT Approval Instead of PCCIT – ITAT Mumbai

Adarsh Developers Vs ITO (ITAT Mumbai) Reopening Beyond 3 Years Invalid – Approval by PCIT Instead of PCCIT Violates Sec 151(ii) – Entire Reassessment Quashed – ITAT Mumbai AO reopened assessment u/s 147 alleging undervaluation of property u/s 43CA & estimated GP addition; CIT(A) upheld reassessment and additions. Assessee raised additional legal grounds challenging validity of notice u/s 148 under new regime. ITAT held that where notice is issued beyond 3 years, approval must be obtained from specified higher authority as per Sec 151(ii). In present case, sanction was granted by PCI...