https://www.taxtmi.com/caselaws?id=783797 Reopening of assessment beyond three years was challenged on the ground of invalid sanction under s.151. The ITAT held that, for issuance of notice under s.148 after three years, statutory approval must be granted by the Pr. CCIT, not the PCIT, and any sanction by the wrong authority is a jurisdictional defect. Since the approval in the case was accorded by the PCIT, the notice under s.148 was void ab initio, rendering the consequent reassessment and the first appellate order unsustainable. The notice, reassessment, and appellate order were quashed and the appeal was allowed. en-us Fri, 14 Nov 2025 00:00:00 +0530 Mon, 22 Dec 2025 15:40:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783797 Reopening of assessment beyond three years was challenged on the ground of invalid sanction under s.151. The ITAT held that, for issuance of notice under s.148 after three years, statutory approval must be granted by the Pr. CCIT, not the PCIT, and any sanction by the wrong authority is a jurisdictional defect. Since the approval in the case was accorded by the PCIT, the notice under s.148 was void ab initio, rendering the consequent reassessment and the first appellate order unsustainable. The notice, reassessment, and appellate order were quashed and the appeal was allowed. Case-Laws Income Tax Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783797