Case Law Analysis
|Income Tax Appellate Tribunal
Section 148 Income Tax Act | Reassessment Notice Invalid If Section 151(2)(b) Approval Not Obtained Within 3 Years : ITAT Delhi
The ITAT Delhi has ruled that a reassessment notice under Section 148 is void if the mandatory prior approval from the Principal Chief Commissioner or Principal Director General of Income Tax under Section 151(2)(b) is obtained more than three years after the end of the relevant assessment year. This sets a strict temporal limit on procedural compliance, impacting all tax authorities issuing reopening notices and reinforcing the need for timely administrative due process in income tax reassessments.