2025 (8) TMI 183

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.... Sr. DRs, ORDER PER SONJOY SARMA, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against the order dated 27.06.2024 of the National Faceless Appeal Centre [hereinafter referred to as 'CIT(A)'] passed u/s 250 of the Income Tax Act (hereinafter referred to as the 'Act'). 2. The assessee is an individual and filed his return of income u/s 139(1) of the Act by decla....

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....nts and supporting documents relating to the property purchased. 3. Aggrieved by the above order, the assessee went in appeal before the ld. CIT(A), where, the appeal of the assessee was dismissed by upholding the order of the Assessing Officer. 4. Dissatisfied with the above order, the assessee is in appeal before the Tribunal contending that the reassessment notice u/s 148 of the Act was b....

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....mpugned order of the ld. CIT(A) by sustaining the order of the Assessing Officer be liable to be set aside by deleting the addition made by the Assessing Officer. 5. On the other hand, the ld. DR relied the decisions of the authorities below. 6. We, after hearing the rival submissions and perusing the materials available on record, find that the notice u/s 148 was issued after the expiry of ....

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....r approval as mandated u/s 151 of the Act is invalid and liable to be quashed. We further note that since in the present case the Assessing Officer failed to obtain requisite approval from PCCIT for issuance of reassessment notice beyond 3 years, the proceedings are deemed to be non-compliance to the statutory requirement under the law and the consequent additions made by the Assessing Officer are....