Case Law Analysis
|Income Tax Appellate Tribunal
Section 151 Income Tax Act | Reassessment Beyond 3 Years Requires PCCIT/CCIT Sanction, Not PCIT Approval : ITAT Kolkata
ITAT Kolkata held that reassessment beyond three years under Section 148 mandates PCCIT or CCIT sanction under Section 151; PCIT approval is jurisdictionally invalid. The tribunal quashed a notice where only PCIT approval was obtained, reinforcing the strict hierarchy for time-barred proceedings and protecting taxpayers from procedurally flawed orders.