Reopening Invalid If Section 148 Notice Issued Before Formal Sanction: ITAT Kolkata

Paras Plaza Pvt. Ltd. Vs ITO (ITAT Kolkata) Reopening u/s 147 Bad in Law Where 148 Notice Precedes Formal Receipt of Sanction u/s 151 though granted earlier- Communication of Sanction Is Mandatory – Internal Approval Not Enough to Validate 148 Notice Assessee filed its return declaring a small loss of ₹27,163, which was processed u/s 143(1). Later, AO reopened the case u/s 147 by issuing a notice u/s 148 dated 26.03.2019, alleging unexplained share transactions of ₹3.8 crore. Assessment was completed u/s 147/143(3) with addition of ₹3.8 crore as unexplained cash credit, which was uphel...