Reassessment u/s 148 Without Approval from Competent Authority u/s 151 is Void ab Initio: ITAT

The Income Tax Appellate Tribunal (ITAT) has definitively ruled that any reassessment initiated under Section 148 of the Income Tax Act without obtaining the necessary approval from the competent authority under Section 151 is void ab initio (void from the beginning). This landmark decision reinforces the critical procedural safeguard embedded in the Income Tax Act for reassessment proceedings. The ITAT emphasized that the approval under Section 151 is not a mere formality but a jurisdictional prerequisite. If this approval is absent or improperly obtained, the entire reassessment proceeding is rendered invalid. This ruling provides significant relief to taxpayers by preventing arbitrary or procedurally flawed reassessments, ensuring strict adherence to statutory mandates by tax authorities.