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ITAT invalidated reassessment proceedings due to procedural irregularities in sanctioning authority under section 151. The tribunal found that the approval for reopening assessment beyond three years was not granted by the competent authority as prescribed under the new regime. The assessment order under section 147 read with sections 144 and 144B was struck down due to lack of valid jurisdictional sanction. The tribunal determined that the revenue's reliance on previous judgments was misplaced, and the assessment order was consequently quashed, rendering the entire reassessment process invalid. The decision was rendered in favor of the assessee, effectively nullifying the tax department's attempt to reopen and reassess the tax liability.
ITAT invalidated reassessment proceedings due to procedural irregularities in sanctioning authority under section 151. The tribunal found that the approval for reopening assessment beyond three years was not granted by the competent authority as prescribed under the new regime. The assessment order under section 147 read with sections 144 and 144B was struck down due to lack of valid jurisdictional sanction. The tribunal determined that the revenue's reliance on previous judgments was misplaced, and the assessment order was consequently quashed, rendering the entire reassessment process invalid. The decision was rendered in favor of the assessee, effectively nullifying the tax department's attempt to reopen and reassess the tax liability.
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