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ITAT held that the reassessment for AY 2018-19 was invalidly initiated because the AO issued notice under section 148 beyond three years without obtaining prior approval from an authority specified under section 151(ii) (Principal Chief Commissioner/Principal Director General or, where absent, Chief Commissioner/Director General). Approval obtained from the Principal Commissioner of Income Tax was not a statutory substitute and therefore did not confer jurisdiction. Consequently, the assessment framed under sections 147 read with 144 and 144B lacked valid assumption of jurisdiction and was quashed. The appeal by the assessee was allowed and the reassessment order set aside.
ITAT held that the reassessment for AY 2018-19 was invalidly initiated because the AO issued notice under section 148 beyond three years without obtaining prior approval from an authority specified under section 151(ii) (Principal Chief Commissioner/Principal Director General or, where absent, Chief Commissioner/Director General). Approval obtained from the Principal Commissioner of Income Tax was not a statutory substitute and therefore did not confer jurisdiction. Consequently, the assessment framed under sections 147 read with 144 and 144B lacked valid assumption of jurisdiction and was quashed. The appeal by the assessee was allowed and the reassessment order set aside.
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