Reassessment Notice invalid if approved by JCIT instead of Pr.CIT after four years

ACIT Vs SBK Trade And Infrastructure Pvt. Ltd. (ITAT Delhi)

Reopening Beyond 4 Years Quashed: ITAT Delhi Applies Rajeev Bansal—JCIT Approval Invalid, 148 Notice Time-Barred; TOLA 2020 does not extend deadlines for notices issued after March 2021

Assessee challenged the reopening u/s 148 on the ground that the approval was taken from the JCIT, Range-22, whereas for a notice issued after four years from the end of AY 2015-16, the law mandates approval of the Pr.CIT u/s 151(1). The notice dated 31.03.2021 was issued with JCIT approval based on the Revenue’s

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