https://www.taxtmi.com/caselaws?id=769292 The ITAT Jaipur held that the section 148 notice was invalid due to improper approval procedures under the new regime. Following the SC's decision in Rajeev Bansal's case, prior approval under section 151 was required for notices issued after 1-04-2021. Although the AO obtained sanction from JCIT Range-4 Jaipur for the section 148 notice, the competent authority for section 148A(d) approval was Pr.CIT-2 Jaipur, creating procedural invalidity. Additionally, the tribunal upheld that reopening assessment for bogus share transactions constituted a change of opinion, as the AO had previously examined all materials during original assessment proceedings and taken a conclusive view. en-us Wed, 12 Mar 2025 00:00:00 +0530 Wed, 23 Apr 2025 09:09:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769292 The ITAT Jaipur held that the section 148 notice was invalid due to improper approval procedures under the new regime. Following the SC's decision in Rajeev Bansal's case, prior approval under section 151 was required for notices issued after 1-04-2021. Although the AO obtained sanction from JCIT Range-4 Jaipur for the section 148 notice, the competent authority for section 148A(d) approval was Pr.CIT-2 Jaipur, creating procedural invalidity. Additionally, the tribunal upheld that reopening assessment for bogus share transactions constituted a change of opinion, as the AO had previously examined all materials during original assessment proceedings and taken a conclusive view. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769292