Reassessment Quashed u/s 151 for Wrong Authority Beyond 3 Years

JD Jewellers Vs ITO (ITAT Delhi) Reassessment Quashed – Approval Taken From Wrong Authority u/s 151; Beyond 3 Years Requires PCCIT Sanction The Assessee challenged reopening u/s 147 r.w.s.144B on the jurisdictional ground that sanction u/s 151 was wrongly obtained from PCIT instead of PCCIT. The record (page 2 of order) shows that reassessment for AY 2017-18 was initiated on 21.07.2022, clearly beyond 3 years from the end of the relevant AY. As per the amended section 151, where reopening is beyond 3 years, the specified sanctioning authority is PCCIT. However, AO obtained sanction only from...