No Section 263 Revision based on Reassessment Order Sanctioned by Wrong Authority

Shreeji Developers Vs PCIT (ITAT Ahmedabad) ITAT Ahmedabad Quashes Section 263 Revision – No Revision Possible on Invalid Reassessment Order Sanctioned by Wrong Authority Ahmedabad ITAT has held that a revisionary order u/s 263 cannot be sustained when the underlying reassessment order itself is invalid in law due to sanction from the wrong specified authority. Assessee’s reassessment u/s 147 r.w.s. 144 was initiated after three years from the end of the relevant AY, requiring sanction from the PCCIT/PDGIT/CCIT/DGIT as per Section 151(ii). However, the sanction was accorded by the PCIT. ...