https://www.taxtmi.com/caselaws?id=463211 The ITAT CUTTACK held that the reassessment notice issued under section 148 after four years lacked valid approval, as it was sanctioned by an incompetent authority, rendering the notice invalid and liable to be quashed. The notice dated 31.03.2021 was deemed served on 01.04.2021, invoking amended provisions under section 148A, but proceedings under the amended law were dropped, leading to quashing of the consequential order. The tribunal also found the notice violated CBDT Instruction No. 1/2011 regarding jurisdiction, confirming that the reassessment proceedings initiated by the subordinate officer without proper authority were invalid. Additionally, payments made by the cooperative society to its members were held not to attract disallowance under section 40A(2)(b) due to the principle of mutuality. The assessee's appeal was allowed. en-us Wed, 04 Sep 2024 00:00:00 +0530 Thu, 14 Aug 2025 16:09:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463211 The ITAT CUTTACK held that the reassessment notice issued under section 148 after four years lacked valid approval, as it was sanctioned by an incompetent authority, rendering the notice invalid and liable to be quashed. The notice dated 31.03.2021 was deemed served on 01.04.2021, invoking amended provisions under section 148A, but proceedings under the amended law were dropped, leading to quashing of the consequential order. The tribunal also found the notice violated CBDT Instruction No. 1/2011 regarding jurisdiction, confirming that the reassessment proceedings initiated by the subordinate officer without proper authority were invalid. Additionally, payments made by the cooperative society to its members were held not to attract disallowance under section 40A(2)(b) due to the principle of mutuality. The assessee's appeal was allowed. Case-Laws Income Tax Wed, 04 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463211