Reassessment Notice Under Section 148 Quashed Due to Improper Sanction by PCIT After Three-Year Limitation Period

The HC quashed reassessment proceedings for AY 2016-17 initiated via notice u/s 148 issued on July 29, 2022. The Court found that since the reassessment action commenced more than three years after the end of the relevant assessment year, sanction should have been accorded by the Principal Chief Commissioner rather than the Principal Commissioner of Income Tax (PCIT). This jurisdictional defect rendered the reassessment proceedings invalid, as the PCIT lacked competent authority to sanction the action after the three-year limitation period had elapsed. The Court allowed the writ petition on this procedural ground alone. .....

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