Reassessment jurisdiction fails when section 148 notice lacks the prescribed sanction under section 151 after three years.

A notice issued under section 148 after more than three years from the end of the relevant assessment year required prior sanction from the authority specified in section 151(ii). Approval from the Principal Commissioner was not sufficient because it was not the competent authority under the statute. The absence of valid sanction went to the root of jurisdiction, so the reopening was invalid. As the notice itself was void, the reassessment order passed under sections 147 and 144 could not be sustained and was quashed.

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Issues: Whether the notice issued under section 148 was invalid for want of approval from the prescribed authority under section 151, and whether the reassessment order could survive on that basis.

Analysis: The notice under section 148 was issued after more than three years from the end of the relevant assessment year. In such a case, section 151(ii) required prior sanction from the Principal Chief Commissioner or Principal Director General or, where applicable, the Chief Commissioner or Director General. The approval was obtained only from the Principal Commissioner of Income Tax, who was not the competent authority under the statutory mandate. The defect went to the root of jurisdiction and rendered the reopening invalid. Once the notice itself was void, the reassessment order passed under sections 147 and 144 could not be sustained.

Conclusion: The notice under section 148 was held invalid and void, and the reassessment order was quashed.

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