Reassessment Quashed – Invalid Sanction by PCIT Instead of PCCIT Beyond 3 Years

Darbari Industries Vs ACIT (ITAT Mumbai) Mumbai ITAT quashed reassessment proceedings holding that approval under Section 151 was obtained from the wrong authority, rendering the entire reopening void ab initio. The Tribunal noted: Notice u/s 148 was issued on 27.04.2023, i.e., beyond 3 years from end of A.Y. 2019-20 As per Section 151(ii), approval in such cases must be from PCCIT (higher authority) However, approval was obtained only from PCIT, which is not valid in law Relying on Bombay HC in Chitra Supekar, the ITAT held: Correct sanction is a jurisdictional requirement Defect in sancti...