Reassessment Quashed as Section 148 Notice Issued Before Mandatory Approval

Bindu Rani Vs ITO (ITAT Delhi)

Approval After Action? Reopening Goes Out of Fashion! – ITAT Quashes 148 Notice Issued Two Days Before Sanction- ITAT Holds Approval Obtained Later Invalidates Proceedings

ITA Nos.4037 & 4054/Del/2024 | AY 2017-18 | Order dt. 27-08-2025

Assessee challenged reassessment & penalty orders passed u/s 147 r.w.s. 144 & 271AAC(1). Her main contention was that the notice u/s 148 dated 28-03-2021 (3:30 PM) was issued before obtaining the mandatory sanction u/s 151, which was granted only on 30-03-2021 (12:14 PM) by

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