Section 151 Sanction by Incorrect Authority Invalidates Section 148 Reassessment: ITAT Delhi

Advertisement Vishesh Developers Pvt. Ltd. Vs ACIT (ITAT Delhi) The Delhi ITAT adjudicated an appeal filed by the assessee against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 16.10.2025 for Assessment Year 2019-20. The principal issue was the validity of reassessment proceedings initiated under Section 148 of the Income Tax Act, 1961 where the notice was issued beyond three years from the end of the relevant assessment year. The assessee contended that the Assessing Officer had reopened the assessment by issuing a notice under Section...