https://www.taxtmi.com/caselaws?id=312427 ITAT Kolkata held that revision u/s 263 was invalid when the underlying reassessment order u/s 147/143(3) was void ab-initio. The AO issued notice u/s 148 beyond four years without mandatory approval from Commissioner-level authorities as required under Section 151(1). Since the statute mandates specific authority satisfaction for such notices, the reassessment order was jurisdictionally invalid and null in law. Following the legal maxim "Sublato Fundamento Credit Opus," all consequential actions including the revision order were deemed void. Decision favored the assessee. en-us Wed, 01 Jan 2020 00:00:00 +0530 Fri, 16 Feb 2024 17:05:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312427 ITAT Kolkata held that revision u/s 263 was invalid when the underlying reassessment order u/s 147/143(3) was void ab-initio. The AO issued notice u/s 148 beyond four years without mandatory approval from Commissioner-level authorities as required under Section 151(1). Since the statute mandates specific authority satisfaction for such notices, the reassessment order was jurisdictionally invalid and null in law. Following the legal maxim "Sublato Fundamento Credit Opus," all consequential actions including the revision order were deemed void. Decision favored the assessee. Case-Laws Income Tax Wed, 01 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312427