Reopening u/s. 148 beyond 3 years based on approval u/s. 151 from Pr. CIT is invalid

ITO Vs Quality Steel Shoppe Private Limited (ITAT Visakhapatnam)

ITAT Vishakhapatnam held that reopening notice u/s. 148 being issued beyond period of three years on the basis of approval u/s. 151(ii) of the Income Tax Act obtained from Pr. Commissioner of Income Tax [Pr. CIT] instead of Principal Chief Commissioner or Principal Director General is invalid and liable to be quashed.

Facts- The assessee company had filed its return of income for AY 2018-19 on 15/09/2018, declaring an income of Rs. NIL. Subsequently, the Jurisdictional Assessing Officer based

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