https://www.taxtmi.com/caselaws?id=773528 ITAT Mumbai quashed reopening notice issued under section 148 beyond three years without proper approval from specified authority as required under section 151. The approval was obtained from Principal Commissioner instead of required Principal Chief Commissioner/Director General. Relying on Ashish Agrawal and Rajeev Bansal SC decisions, the notice dated 31.07.2022 for AY 2017-18 was held invalid. Additionally, section 56(2)(viia) addition was deleted as difference between purchase consideration and stamp duty valuation was only 8.27%, below the 10% threshold. Assessee appeal allowed on both legal and merit grounds. en-us Fri, 20 Jun 2025 00:00:00 +0530 Tue, 24 Jun 2025 08:25:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773528 ITAT Mumbai quashed reopening notice issued under section 148 beyond three years without proper approval from specified authority as required under section 151. The approval was obtained from Principal Commissioner instead of required Principal Chief Commissioner/Director General. Relying on Ashish Agrawal and Rajeev Bansal SC decisions, the notice dated 31.07.2022 for AY 2017-18 was held invalid. Additionally, section 56(2)(viia) addition was deleted as difference between purchase consideration and stamp duty valuation was only 8.27%, below the 10% threshold. Assessee appeal allowed on both legal and merit grounds. Case-Laws Income Tax Fri, 20 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773528