Reassessment Quashed for Wrong Sanction: Notice Issued Without Mandatory PCCIT Approval

Shabbir Taheri Vs ITO (ITAT Mumbai)

The appeal concerns the assessee’s challenge to the reassessment proceedings initiated for Assessment Year (AY) 2018-19 through a notice issued under Section 148 of the Income-tax Act on 06 April 2022 after obtaining approval from the Principal Commissioner of Income Tax (PCIT), Mumbai-17. The assessee contended that the reopening was invalid because, as per Section 151(ii) of the Act, once three years had elapsed from the end of the relevant assessment year, approval for issuing notice under Sections 148 and 148A(d) must come from the P

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