Non-compliance With Amended Provisions of S.148A and S.151: ITAT Invalidates Reassessment Notice Issued After 5 Years

The ITAT (Income Tax Appellate Tribunal) has invalidated a "reassessment notice issued after 5 years," citing "non-compliance with amended provisions of Section 148A and Section 151." Section 148A requires a preliminary inquiry and a show-cause notice before issuing a reassessment notice, while Section 151 mandates specific approvals for notices issued beyond certain timelines. The tribunal found that the tax authorities failed to adhere to these crucial amended procedures, especially for notices issued beyond the stipulated period, rendering the entire reassessment proceeding void due to fundamental procedural flaws.