https://www.taxtmi.com/caselaws?id=782793 ITAT Kolkata (AT) held that the reassessment proceedings were invalid as the notice under s.148 was issued beyond three years from the end of the relevant assessment year on the basis of approval granted by the Pr.CIT instead of the statutorily mandated Pr.CCIT under s.151. The Tribunal held that the jurisdictional pre-condition for valid reopening was not satisfied, rendering the sanction incompetent and the notice void ab initio. Consequently, the reassessment order passed pursuant to such invalid notice was quashed in entirety, and the assessee's appeal was allowed. en-us Tue, 26 Aug 2025 00:00:00 +0530 Thu, 04 Dec 2025 09:19:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782793 ITAT Kolkata (AT) held that the reassessment proceedings were invalid as the notice under s.148 was issued beyond three years from the end of the relevant assessment year on the basis of approval granted by the Pr.CIT instead of the statutorily mandated Pr.CCIT under s.151. The Tribunal held that the jurisdictional pre-condition for valid reopening was not satisfied, rendering the sanction incompetent and the notice void ab initio. Consequently, the reassessment order passed pursuant to such invalid notice was quashed in entirety, and the assessee's appeal was allowed. Case-Laws Income Tax Tue, 26 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782793