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ITAT quashed reassessment notice under section 148 issued beyond three years from relevant Assessment Year due to invalid prior approval. The Assessing Officer obtained approval from Principal Commissioner instead of specified authority as mandated under section 151(ii), which requires approval from Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General for notices beyond three-year period. Consequently, the entire reopening proceedings and reassessment order were declared invalid. Additionally, ITAT deleted addition under section 56(2)(viia) as the difference between actual consideration and stamp duty valuation was only 8.27%, falling below the 10% threshold for applicability of deemed income provisions. The assessee's appeal was allowed on both legal and merit grounds, with all additions quashed.
ITAT quashed reassessment notice under section 148 issued beyond three years from relevant Assessment Year due to invalid prior approval. The Assessing Officer obtained approval from Principal Commissioner instead of specified authority as mandated under section 151(ii), which requires approval from Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General for notices beyond three-year period. Consequently, the entire reopening proceedings and reassessment order were declared invalid. Additionally, ITAT deleted addition under section 56(2)(viia) as the difference between actual consideration and stamp duty valuation was only 8.27%, falling below the 10% threshold for applicability of deemed income provisions. The assessee's appeal was allowed on both legal and merit grounds, with all additions quashed.
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