Reopening Quashed for Invalid Section U/s 151 – Approval by Wrong Authority Beyond 3 Years Held Void – ITAT Mumbai

Surat Goods Transport Pvt. Ltd. Vs DCIT (ITAT Mumbai)

The assessee challenged reassessment initiated u/s 148 where addition of ₹5.04 lakh was made on interest paid on alleged bogus loan. The key issue was validity of sanction under section 151 since reopening notice dated 07.04.2022 was issued after three years from the end of AY 2018-19, requiring approval from the higher specified authority (PCCIT/CCIT). However, sanction was granted by PCIT, who lacked jurisdiction under section 151(ii).

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