https://www.taxtmi.com/caselaws?id=782377 ITAT Jaipur held that the reassessment notice issued u/s 148 and the order u/s 148A(d) were invalid as the mandatory sanction under the new regime u/s 151 was obtained from the PCIT instead of the higher authorities (PCCI/PDGIT/CCIT/DGIT) required where notice is issued beyond three years from the end of the relevant assessment year. Relying on SC rulings in Rajeev Bansal and Ashish Agarwal and Delhi HC in Kusum Healthcare, the Tribunal ruled that TOLA only extended limitation and did not alter the sanction hierarchy. The notice and consequential assessment were quashed and the assessee's appeal allowed. en-us Wed, 19 Nov 2025 00:00:00 +0530 Wed, 26 Nov 2025 16:48:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782377 ITAT Jaipur held that the reassessment notice issued u/s 148 and the order u/s 148A(d) were invalid as the mandatory sanction under the new regime u/s 151 was obtained from the PCIT instead of the higher authorities (PCCI/PDGIT/CCIT/DGIT) required where notice is issued beyond three years from the end of the relevant assessment year. Relying on SC rulings in Rajeev Bansal and Ashish Agarwal and Delhi HC in Kusum Healthcare, the Tribunal ruled that TOLA only extended limitation and did not alter the sanction hierarchy. The notice and consequential assessment were quashed and the assessee's appeal allowed. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782377