Reassessment Quashed: ITAT Rules Wrong Approval Invalidates Bogus LTCG Reopening Beyond 3 Years

Ajit Pal Singh Choudhary Vs ACIT (ITAT Delhi)

ITAT Quashes Reassessment for Invalid Sanction Beyond 3 Years- Reopening Beyond Three Years with Wrong Approval—ITAT Quashes Bogus LTCG Reassessment

Assessee declared ₹10.56 lakh income and claimed exempt LTCG of ₹1.10 crore. AO reopened the case alleging bogus LTCG from penny stock and added ₹1,09,89,382 u/s 69A. CIT(A) upheld the addition.

Before ITAT, Assessee argued that the notice u/s 148 was issued on 19.07.2022, i.e., beyond 3 years from AY 2016-17, so Section 151(ii) requir

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