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    <title>2025 (10) TMI 1388 - ITAT PUNE</title>
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    <description>Where reassessment is initiated more than three years after the end of the relevant assessment year, section 151 of the Income-tax Act requires approval from the Principal Chief Commissioner or Chief Commissioner. Here, the notices under sections 148A(d) and 148 were issued beyond that period, but approval was taken from the Principal Commissioner instead. That defect was treated as a mandatory statutory violation, and the invalid sanction deprived the reassessment notice and ensuing proceedings of jurisdiction. The notice was therefore held invalid and the reassessment proceedings were quashed in favour of the assessee.</description>
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    <pubDate>Wed, 29 Oct 2025 00:00:00 +0530</pubDate>
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      <title>2025 (10) TMI 1388 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=467854</link>
      <description>Where reassessment is initiated more than three years after the end of the relevant assessment year, section 151 of the Income-tax Act requires approval from the Principal Chief Commissioner or Chief Commissioner. Here, the notices under sections 148A(d) and 148 were issued beyond that period, but approval was taken from the Principal Commissioner instead. That defect was treated as a mandatory statutory violation, and the invalid sanction deprived the reassessment notice and ensuing proceedings of jurisdiction. The notice was therefore held invalid and the reassessment proceedings were quashed in favour of the assessee.</description>
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      <pubDate>Wed, 29 Oct 2025 00:00:00 +0530</pubDate>
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