Jurisdictional approval in reassessment proceedings is mandatory; invalid sanction under the statutory hierarchy can quash the notice and proceedings.

A liberal approach to sufficient cause was applied, and a 79-day delay in filing the appeal was condoned because the explanation based on limited legal awareness, reliance on an accountant, and urgency over bank account attachment was found bona fide. In reassessment proceedings under the post-2021 regime, prior approval in the prescribed statutory hierarchy was treated as a jurisdictional precondition for issuing the notice and proceeding further. Because the approval was granted by an authority not competent under the applicable time-limit structure, the reassessment notice was held invalid and the consequential proceedings were quashed.

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Issues: (i) Whether the delay of 79 days in filing the appeal deserved condonation on showing sufficient cause. (ii) Whether the reassessment notice and the consequential proceedings were valid when approval under the reassessment provisions was granted by an authority not competent under the applicable time-limit structure.

Issue (i): Whether the delay of 79 days in filing the appeal deserved condonation on showing sufficient cause.

Analysis: The delay was explained on the basis of the assessee's limited legal awareness, reliance on the accountant, and the need to deal urgently with attachment and release of the bank account. The explanation was found to be bona fide and not motivated by dilatory conduct. A liberal approach to "sufficient cause" was applied to advance substantial justice.

Conclusion: The delay of 79 days was condoned and the appeal was admitted.

Issue (ii): Whether the reassessment notice and the consequential proceedings were valid when approval under the reassessment provisions was granted by an authority not competent under the applicable time-limit structure.

Analysis: Under the post-2021 reassessment regime, prior approval under the specified statutory hierarchy is a jurisdictional precondition for issuing a notice and for passing the order deciding whether reassessment should proceed. Where the alleged escapement was below the threshold and more than three years had elapsed from the end of the assessment year, approval could not lawfully be granted by the authority that sanctioned it in this case. Non-compliance with the prescribed approval requirement affected jurisdiction and rendered the reassessment notice invalid.

Conclusion: The notice under reassessment was held to be bad in law and was quashed, with the consequential proceedings also falling.

Final Conclusion: The assessee succeeded, the reassessment was annulled on jurisdictional grounds, and the merits of the addition were rendered academic.

Ratio Decidendi: In reassessment proceedings, compliance with the statutorily prescribed approval hierarchy is a jurisdictional condition precedent, and breach of that requirement invalidates the notice and all consequent proceedings.

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