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Wrong Sanction, Dead Reopening: Delhi ITAT Quashes 148A(d) Order for AY 2017-18
Case Law Details
- Case Name
- DCIT Vs Pankaj Goel (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Delhi
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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...
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