Wrong Sanction, Dead Reopening: Delhi ITAT Quashes 148A(d) Order for AY 2017-18

DCIT Vs Pankaj Goel (ITAT Delhi) Wrong Sanction, Dead Reopening: Delhi ITAT Quashes 148A(d) Order for AY 2017-18 Delhi ITAT dismissed the Revenue’s appeal and allowed the Assessee’s cross-objection, holding that the reopening u/s 147 was void ab initio due to approval taken from an incompetent authority u/s 151(ii). The reassessment proceedings were initiated by issuing notice u/s 148A(d) dated 30.07.2022 for AY 2017-18, i.e., beyond three years from the end of the relevant assessment year. However, the Assessing Officer obtained approval from the PCIT (Central-01), Delhi, instead of the P...