Reassessment Quashed as Notice Beyond 3 Years Approved by Wrong Authority

Smurti Waghdhare Vs DCIT (ITAT Chennai) In this case, the reassessment was initiated based on cash deposits and withdrawals, with the AO treating the entire amounts as unexplained u/s 69A. Before the ITAT, the assessee raised a jurisdictional challenge: The notice u/s 148 was issued beyond 3 years from the end of the relevant AY, However, approval was obtained from PCIT instead of PCCIT, as required under section 151(1)(ii). The Tribunal held: The correct sanctioning authority depends on timing of the 148 notice-not 148A(b). Even if 148A(b) notice was within 3 years, 148 notice issued after...