https://www.taxtmi.com/caselaws?id=783190 ITAT Rajkot allowed the assessee's appeal and quashed the reassessment. It held that for A.Y. 2013-14, the outer limitation for issuance of notice under s.148 expired on 31.03.2020, whereas the notice was issued on 16.04.2021, rendering it time-barred and inherently invalid. Further, sanction for issue of notice was obtained from the PCIT instead of the PCCIT, contrary to the mandatory requirement of s.151, vitiating the jurisdiction. The Tribunal held that these jurisdictional defects are not curable under s.292BB, as the basic preconditions for a valid reassessment were not satisfied. en-us Fri, 28 Nov 2025 00:00:00 +0530 Tue, 09 Dec 2025 18:30:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783190 ITAT Rajkot allowed the assessee's appeal and quashed the reassessment. It held that for A.Y. 2013-14, the outer limitation for issuance of notice under s.148 expired on 31.03.2020, whereas the notice was issued on 16.04.2021, rendering it time-barred and inherently invalid. Further, sanction for issue of notice was obtained from the PCIT instead of the PCCIT, contrary to the mandatory requirement of s.151, vitiating the jurisdiction. The Tribunal held that these jurisdictional defects are not curable under s.292BB, as the basic preconditions for a valid reassessment were not satisfied. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783190