Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT held that the reassessment notice u/s. 148 issued on 29.07.2022 was invalid due to procedural non-compliance. The three-year limitation period had lapsed, and the approval was not obtained from the specified authority as mandated under the new regime. The notice violated sections 149(1) and 151 of the Income Tax Act, as the approval was sought from an unauthorized Principal Commissioner instead of the Principal Chief Commissioner or Director General. Consequently, the tribunal quashed the reassessment notice, thereby allowing the assessee's appeal and rendering the proceedings null and void.
ITAT held that the reassessment notice u/s. 148 issued on 29.07.2022 was invalid due to procedural non-compliance. The three-year limitation period had lapsed, and the approval was not obtained from the specified authority as mandated under the new regime. The notice violated sections 149(1) and 151 of the Income Tax Act, as the approval was sought from an unauthorized Principal Commissioner instead of the Principal Chief Commissioner or Director General. Consequently, the tribunal quashed the reassessment notice, thereby allowing the assessee's appeal and rendering the proceedings null and void.
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