ITAT Quashes Reassessment as Section 148 Approval Was Obtained from PCIT Instead of Pr. CCIT:

The assessee is Papaiah Arjun who filed an appeal against the order dated 2 June 2025 passed by the CIT(A) for Assessment Year 2018-19. The AO had issued a notice dated 5 April 2022 under Section 148 of the Income Tax Act, 1961, to reopen the assessment. The assessee challenged the validity of the notice on the ground that, since it was issued beyond three years, approval was required from the Pr. CCIT. However, the approval had been obtained from the PCIT instead.

The Tribunal observed that the notice dated 5 April 2022 was issued beyond three years and that the requisite approval had been obtained from the PCIT instead of the Pr. CCIT. The Tribunal further noted that the Madras High Court had upheld the earlier Tribunal decision by order dated 12 June 2026, finding no error or infirmity in its conclusions and dismissing the substantial questions of law raised by the Revenue.

Applying the same reasoning, the Tribunal held that the notice issued under Section 148 in the present case was invalid and that the reassessment proceedings based on it could not be sustained. Accordingly, the Tribunal quashed the reassessment and allowed the assessee's appeal.