Reassessment Quashed – Invalid Sanction u/s 151(ii) by PCIT After 3 Years: ITAT Chennai

Palanisamy Shankarganesh Vs ITO (ITAT Chennai) Reassessment quashed for wrong sanction u/s 151(ii) – Approval by PCIT invalid after 3 years – ITAT Chennai In Palanisamy Shankarganesh vs ITO (A.Y. 2018-19), reassessment was initiated alleging bogus purchases based on investigation wing information. The AO issued notice u/s 148 on 05.04.2022, beyond three years from the end of the assessment year, after obtaining approval only from the Principal Commissioner. The ITAT admitted additional legal grounds and examined section 151. It held that where more than three years have elapsed, approval m...