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Section 148 Notice Invalid Without PCIT/PCDG Sanction After 3 Years
Case Law Details
- Case Name
- Venkata Prasad Pulipati Vs ITO (ITAT Visakhapatnam)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2016-17
- Courts
- All ITAT, ITAT Visakhapatnam
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Venkata Prasad Pulipati Vs ITO (ITAT Visakhapatnam)
Wrong Boss Signed, Reopening Dies: ITAT Quashes 148 for Want of PCIT/PCDG Sanction
The Visakhapatnam Bench of the ITAT quashed the reassessment framed u/s 147 r.w.s. 144B for AY 2016-17 on the ground of lack of valid sanction u/s 151. The notice u/s 148 dated 27-07-2022 was issued beyond three years from the end of the relevant AY. As per Section 151(ii) (post-Finance Act, 2021), such reopening mandatorily requires approval of the Principal Chief Commissioner / Principal Director General (or CCIT/DG).
In the present case, the approval was obt...
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