Held that notice under section 148 was issued after expiry of three years from the end of the relevant assessment year without obtaining approval from the competent authority as prescribed under section 151(ii); reassessment proceedings were invalid. (AY. 2017-18)
Karia Builders. v. ITO (2025) 214 ITD 161 (Pune) (Trib.)
S. 151: Reassessment-Sanction for issue of notice –Notice under section 148 was issued after expiry of three years from the end of the relevant assessment year without approval from the authority prescribed under section 151(ii)-Reassessment proceedings were invalid. [S. 148, 151(ii)]
Leave a Reply