https://www.taxtmi.com/caselaws?id=767781 The ITAT Ahmedabad upheld the AO's reopening of assessment under Section 147, rejecting the assessee's challenge that mandatory PCIT/CIT permission was not obtained before issuing notice under Section 148. The tribunal found the case fell under Section 151(2), which permits notice issuance with JCIT authority after four years when no regular assessment under Section 143(3) occurred, as the return was only processed under Section 143(1). However, the tribunal partly allowed the appeal by restricting disallowance of cartage expenses to 15%, following precedent from the identical facts in A.Y. 2011-12. en-us Fri, 21 Mar 2025 00:00:00 +0530 Tue, 25 Mar 2025 08:48:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767781 The ITAT Ahmedabad upheld the AO's reopening of assessment under Section 147, rejecting the assessee's challenge that mandatory PCIT/CIT permission was not obtained before issuing notice under Section 148. The tribunal found the case fell under Section 151(2), which permits notice issuance with JCIT authority after four years when no regular assessment under Section 143(3) occurred, as the return was only processed under Section 143(1). However, the tribunal partly allowed the appeal by restricting disallowance of cartage expenses to 15%, following precedent from the identical facts in A.Y. 2011-12. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767781