#Ashish Agarwal case

ITAT Agra rules reassessment notices under Section 148 of the Income Tax Act issued after 30.06.2021 are time-barred under the Taxation and Other Laws Act (TOLA), invalidating additions exceeding Rs. 23 crore. The judgment reinforces strict adherence to limitation periods, impacting taxpayers facing delayed reassessment proceedings.

ITAT Mumbai ruled that reassessment proceedings initiated beyond three years from the relevant assessment year are invalid if approved by an incorrect authority under Section 151(ii) of the Income Tax Act. The tribunal held that only the 'specified authority' as amended in 2021 could grant approval, rendering the notice and subsequent proceedings null and void. This decision reinforces jurisdictional compliance in tax reassessment cases, impacting taxpayers and revenue authorities alike.

ITAT Delhi sets aside a reassessment order for AY 2017-18, ruling that if more than three years have elapsed since the original assessment, approval under Section 151(ii) must be granted by the Principal Chief Commissioner-not the Principal Commissioner-to validate proceedings. The decision reinforces strict compliance with statutory approval hierarchies in tax reassessment cases.