https://www.taxtmi.com/caselaws?id=462860 The ITAT Mumbai ruled in favor of the assessee, holding that reassessment notices issued under Section 148 were invalid on two grounds. First, regarding limitation, the tribunal followed the SC ruling in Rajeev Bansal, determining that for AY 2015-16, the notice issued on 30/06/2022 exceeded the surviving time limit despite TOLA relaxations extending deadlines to 30/06/2021. The CIT(A)'s reliance on Ashish Agarwal and the extended limitation period under Section 149(1)(b) was rejected. Second, concerning sanction validity under Section 151(ii), the tribunal found that notices issued after three years from the assessment year end required sanction from the Principal Chief Commissioner or Principal Director General, not the Principal Commissioner who actually provided approval. Following precedent from Manish Financials, the improper sanctioning authority rendered the notices legally invalid. Consequently, the subsequent assessment proceedings were declared null and void, and the assessee's appeal was allowed. en-us Tue, 31 Dec 2024 00:00:00 +0530 Mon, 21 Jul 2025 19:11:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462860 The ITAT Mumbai ruled in favor of the assessee, holding that reassessment notices issued under Section 148 were invalid on two grounds. First, regarding limitation, the tribunal followed the SC ruling in Rajeev Bansal, determining that for AY 2015-16, the notice issued on 30/06/2022 exceeded the surviving time limit despite TOLA relaxations extending deadlines to 30/06/2021. The CIT(A)'s reliance on Ashish Agarwal and the extended limitation period under Section 149(1)(b) was rejected. Second, concerning sanction validity under Section 151(ii), the tribunal found that notices issued after three years from the assessment year end required sanction from the Principal Chief Commissioner or Principal Director General, not the Principal Commissioner who actually provided approval. Following precedent from Manish Financials, the improper sanctioning authority rendered the notices legally invalid. Consequently, the subsequent assessment proceedings were declared null and void, and the assessee's appeal was allowed. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462860