https://www.taxtmi.com/caselaws?id=782653 ITAT Delhi allowed the assessee's appeal, holding the reassessment proceedings invalid due to lack of proper sanction under s.151. The order under s.148A(d) was passed on 29.07.2022 and notice u/s 148 issued on 30.07.2022, i.e., beyond three years from the end of the relevant assessment year. In such cases, statutory approval was required from the PCCIT, but sanction was erroneously obtained from the PCIT. Treating this jurisdictional defect as fatal, ITAT quashed the reassessment proceedings and allowed the additional ground challenging reopening. en-us Fri, 28 Nov 2025 00:00:00 +0530 Tue, 02 Dec 2025 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782653 ITAT Delhi allowed the assessee's appeal, holding the reassessment proceedings invalid due to lack of proper sanction under s.151. The order under s.148A(d) was passed on 29.07.2022 and notice u/s 148 issued on 30.07.2022, i.e., beyond three years from the end of the relevant assessment year. In such cases, statutory approval was required from the PCCIT, but sanction was erroneously obtained from the PCIT. Treating this jurisdictional defect as fatal, ITAT quashed the reassessment proceedings and allowed the additional ground challenging reopening. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782653