#Reassessment Jurisdiction

The Delhi ITAT has ruled that a reassessment notice under Section 148 is legally void if the assessing officer fails to obtain mandatory prior approval under Section 151, reinforcing procedural safeguards for taxpayers. This decision impacts all reassessment proceedings initiated after search and survey actions, requiring strict compliance with approval protocols to avoid nullification.

Delhi ITAT rules that reassessment proceedings beyond three years from the assessment year are void if sanctioned by the Principal Commissioner of Income Tax (PCIT) instead of the Principal Chief Commissioner of Income Tax (PCCIT). The ruling underscores strict compliance with Section 151, invalidating reassessment notices issued without proper authority.

ITAT Agra nullified a reassessment under Section 147 after finding the Section 151 approval was a rubber-stamp endorsement without application of mind, reinforcing that procedural compliance is jurisdictional, not formalistic. This ruling impacts all reassessment proceedings where approvals are boilerplate, requiring tax officers to demonstrate genuine scrutiny before reopening assessments.

ITAT Ahmedabad quashes reassessment proceedings for AY 2017-18, ruling that escaped income below Rs. 50 lakhs does not trigger jurisdiction under Section 149(1)(b) of the Income Tax Act. The decision reinforces the statutory threshold as a non-negotiable precondition for reassessment beyond three years, impacting tax authorities' powers to reopen closed assessments.