#Section 151 Income Tax Act

ITAT Bangalore nullified a reassessment order for failure to obtain mandatory approval from the Principal Chief Commissioner under Section 151(2) for notices issued beyond three years. The ruling reinforces strict procedural compliance in income tax reassessment proceedings, impacting taxpayers and revenue authorities alike.

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 Delhi sets aside a reassessment notice under Section 148 of the Income Tax Act for lack of valid sanction under Section 151, emphasizing strict procedural compliance. The ruling nullifies a Rs. 9.91 lakh addition, reinforcing that jurisdictional defects cannot be cured post-facto and safeguarding assessees from arbitrary reassessments.