https://www.taxtmi.com/caselaws?id=782301 ITAT Delhi-AT held that the reassessment initiated u/s 147 was invalid as the mandatory approval u/s 151 was obtained from the PCIT instead of the competent authority, i.e., the PCCIT, because the reopening was beyond three years from the end of the relevant assessment year. The Tribunal followed HC rulings that provisions of TOLA do not alter the identification of the specified sanctioning authority under s.151. As the sanction was undisputedly granted only by the PCIT, the reassessment proceedings were vitiated in law. The reassessment was quashed and the assessee's appeal was allowed. en-us Wed, 19 Nov 2025 00:00:00 +0530 Mon, 24 Nov 2025 17:10:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782301 ITAT Delhi-AT held that the reassessment initiated u/s 147 was invalid as the mandatory approval u/s 151 was obtained from the PCIT instead of the competent authority, i.e., the PCCIT, because the reopening was beyond three years from the end of the relevant assessment year. The Tribunal followed HC rulings that provisions of TOLA do not alter the identification of the specified sanctioning authority under s.151. As the sanction was undisputedly granted only by the PCIT, the reassessment proceedings were vitiated in law. The reassessment was quashed and the assessee's appeal was allowed. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782301