On appeal the assessee contended that the approval under section 151 was granted after issuance of notice under section 148 dated 29-3-2018, since Assessing Officer had received approval from Pr. Commissioner on ITBA Portal on 29-03-2018, however, manual communication through letter was forwarded to Assessing Officer on 31-03-2018 hence bad in law. The Tribunal held that the date of approval was 29-03-2018, which was on ITBA portal of department, and not the date on which communicated to the assessee. Accordingly there was proper compliance of pre-requisite conditions to obtain approval under section 151 as per mandate of law. (AY. 2011-12)
Prem Singh Saluja. v. ITO (2025) 211 ITD 496 (Raipur) (Trib.)
S. 151 : Reassessment-Sanction for issue of notice-Date of sanction for issuance of notice-Date on which the notice is uploaded on ITBA portal of department-Not the date on which was communicated manually. [S. 148]
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