Section 148 Notice Invalid Due to Defective Sanction: ITAT Delhi

ACIT Vs Munjal Holdings (ITAT Delhi) Wrong Sanction Under Amended Section 151 Is Fatal: ITAT Upholds Quashing of Reassessment Despite Rajeev Bansal The Delhi Bench “E” of the ITAT, in ACIT v. Munjal Holdings (AY 2016-17), dismissed the Revenue’s appeal and upheld the CIT(A)’s order quashing the reassessment, holding that the notice under section 148 dated 30.07.2022 was void for want of proper sanction under amended section 151(ii). The assessee’s original assessment under section 143(3) had accepted the returned income. Reassessment was later initiated based on information alleging ...