Reopening Quashed for Wrong Section 151 Approval: Tribunal Finds Jurisdictional Defect After 3 Years

ITO Vs Kolahai Infotech Private Limited (ITAT Delhi) PCIT Approval Not Enough After 3 Years—Tribunal Applies Rajeev Bansal- Jurisdictional Defect Fatal: Wrong Approval Under s.151(ii) Invalidates Entire 147 Proceedings Revenue appealed against order of CIT(A), while Assessee filed cross objections challenging reopening u/s 147 on the ground that notice u/s 148 was issued without obtaining mandatory sanction from the specified authority prescribed u/s 151 of the new regime. For AY 2016-17, notice u/s 148 was issued on 27.07.2022—more than 3 years from end of relevant AY. Under s.151(ii), ap...