https://www.taxtmi.com/caselaws?id=785792 ITAT considered validity of reopening notices issued as section 148/148A(b) and whether the TOLA limitation regime applied; it found TOLA inapplicable for the assessment year where escaped income exceeded Rs. 50 lakh, so notices treated as section 148A(b) were invalid, and consequent orders under the re-opening provisions lacked jurisdiction. The tribunal also held that the assessing officer failed to obtain the prescribed prior approval from the competent authority under the post-amendment approval route, rendering the section 148A(b) order and subsequent section 148/147 actions invalid. Appeal was allowed. en-us Wed, 28 Jan 2026 00:00:00 +0530 Sat, 31 Jan 2026 08:55:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785792 ITAT considered validity of reopening notices issued as section 148/148A(b) and whether the TOLA limitation regime applied; it found TOLA inapplicable for the assessment year where escaped income exceeded Rs. 50 lakh, so notices treated as section 148A(b) were invalid, and consequent orders under the re-opening provisions lacked jurisdiction. The tribunal also held that the assessing officer failed to obtain the prescribed prior approval from the competent authority under the post-amendment approval route, rendering the section 148A(b) order and subsequent section 148/147 actions invalid. Appeal was allowed. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785792