Reassessment Notices Quashed Due to Approval by Wrong Authority Under Section 151

Abhinav Jindal HUF Vs ITO (Delhi High Court) The Delhi High Court considered a batch of writ petitions challenging reassessment notices issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2015–16. The principal ground of challenge was violation of Section 151, specifically regarding the authority competent to grant sanction for initiating reassessment. The petitioners contended that the impugned reassessment notices, issued after the expiry of four years from the end of the relevant assessment year, required mandatory approval from higher authorities such as the Principa...