#Section 151

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.

An unsigned or undated sanction under section 151 of the Income-Tax Act is invalid, making any subsequent section 148 notice jurisdictionless. The Delhi ITAT therefore quashed the assessment notice, safeguarding taxpayers from assessments based on defective approvals.

ITAT Delhi quashes reassessment for AY 2012-13 after finding the prescribed authority’s Section 151 approval lacked independent application of mind. Ruling reaffirms that mechanical approvals violate judicial discipline and render reopening proceedings invalid under CIT vs. S. Goyanka Lime and Chemical Pvt. Ltd. (2015).

ITAT Delhi invalidates reassessment proceedings where the notice under Section 148 was issued beyond three years without approval from the Principal Chief Commissioner of Income Tax (PCCIT). The ruling underscores strict jurisdictional compliance, affecting all taxpayers facing late reassessment notices under the Income Tax Act.

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 Bangalore holds that reassessment proceedings under Section 151 of the Income Tax Act are invalid without a duly signed sanction order, quashing assessment orders for AY 2015-16 to 2017-18. The ruling reinforces strict compliance with procedural safeguards, impacting taxpayers facing arbitrary reassessment notices.

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.

The ITAT Delhi has ruled that any reassessment notice issued under Section 148 after three years from the end of the assessment year is void unless prior approval is obtained from the Principal Chief Commissioner of Income Tax, as mandated by Section 151(ii). This reinforces strict procedural compliance, protecting taxpayers from arbitrary reopening of closed assessments and setting a binding precedent for all assessing officers handling delayed reassessments.

ITAT Delhi rules that reassessment notices issued under Section 148 of the Income Tax Act beyond three years from the assessment year's end are invalid without approval from the Principal Chief Commissioner of Income Tax (PCCIT). The ruling reinforces procedural compliance, impacting taxpayers facing late reassessment proceedings.

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 Delhi holds that for reassessment initiated after three years, approval under Section 151 must be obtained from Principal Chief Commissioner of Income Tax, not lower authorities.