Wrong Authority Approval Voids Reassessment Beyond 3 Years

Sanjeev Kumar Nalam Hyderabad Vs ITO (ITAT Hyderabad) Wrong Sanction, No Jurisdiction: Hyderabad ITAT Quashes Reassessment Issued Beyond 3 Years for Want of Approval u/s 151(ii) Hyderabad ITAT (B-Bench) in Shri Sanjeev Kumar Nalam vs. ITO, Ward-1, Adilabad (ITA No.669/Hyd/2025, AY 2017-18, order dated 19.12.2025) quashed the reassessment framed u/s 147 r.w.s. 144 on the sole legal ground of lack of valid sanction u/s 151. The Tribunal held that the notice u/s 148 dated 29.07.2022 was issued beyond three years from the end of the relevant AY and yet approval was taken only from the Principal Co...