Reassessment approval under section 151 treated as jurisdictional issue, with interim stay granted on the challenged notices.

Reassessment proceedings were challenged on the ground that the notices under section 148, the section 148A(b) notice, the order dated 27.07.2022, and the consequential section 148 notice lacked valid approval under section 151 of the Income-tax Act, 1961. The validity of the approval was treated as a jurisdictional issue going to the root of the reassessment process, and the same question was noted as arising in other pending writ petitions. Pending further consideration, interim protection was granted and the reassessment proceedings were stayed until further directions.

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Issues: Whether the reassessment notices and order were vulnerable for want of valid approval under Section 151 of the Income-tax Act, 1961, and whether interim protection ought to be granted.

Analysis: The petition challenged the notice issued under Section 148, the notice under Section 148A(b), the order dated 27.07.2022, and the consequential notice under Section 148, on the ground that the approval for initiating reassessment was not in conformity with Section 151. The issue was treated as going to the root of jurisdiction, and it was noted that the same question arose in other pending writ petitions. Pending further consideration, notice was issued and the reassessment proceedings were directed to remain stayed.

Conclusion: Interim protection was granted and the reassessment proceedings were stayed until further directions.

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