Reassessment Quashed – Notice U/s 148 Issued Before Approval & Mechanical Sanction U/s 151

Dhansamridhi Finance Pvt. Ltd. Vs ACIT (ITAT Delhi) The ITAT Delhi allowed the assessee’s appeal and quashed reassessment proceedings for AY 2011-12 holding that jurisdictional defects vitiated the entire assessment. The Tribunal noted that notice u/s 148 was issued on 31.03.2018 whereas mandatory approval u/s 151 by the PCIT was granted later on 30.09.2018 (as evident from approval documents reproduced on pages 7-8), making the reopening invalid for want of prior sanction. Further, the Tribunal held that even otherwise the approval was mechanical since the PCIT merely wrote “Yes, Approved...