Reassessment approval under section 151(ii) is jurisdictional; defective sanction invalidates the reopening and quashes proceedings.

Reassessment initiated after the expiry of three years from the end of the relevant assessment year required prior approval from the higher specified authority under section 151(ii) as a jurisdictional precondition for issuing notice under section 148. Applying Union of India v. Rajeev Bansal, the ITAT held that the nature of approval depends on the elapsed time from the assessment year and that non-compliance with the prescribed sanction requirement vitiates the reopening. Because the approval obtained was not the one mandated by the applicable regime, the reassessment proceedings were invalid and were quashed.

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Issues: Whether reassessment proceedings were valid in the absence of approval from the specified authority under section 151(ii) of the Income-tax Act, 1961.

Analysis: The reassessment notice was issued after the expiry of three years from the end of the relevant assessment year, so the applicable approval regime was the one requiring sanction from the higher specified authority under section 151(ii). The decision in Union of India v. Rajeev Bansal was applied to hold that the nature of the approval depends on the elapsed time from the end of the assessment year and that compliance with the prescribed authority requirement is a jurisdictional precondition for issuing notice under section 148. On the facts, the approval obtained was not the approval mandated by the applicable regime, rendering the reopening unsustainable.

Conclusion: The reassessment proceedings were invalid for want of valid approval under section 151(ii) and were quashed; the assessee succeeded.

Final Conclusion: The reopened assessment could not survive the jurisdictional defect in sanction, and the resulting additions or merits became academic.

Ratio Decidendi: Where reassessment is initiated beyond the prescribed period, the authority specified in section 151(ii) must grant prior approval as a jurisdictional condition; failure to obtain that approval invalidates the notice and the consequent reassessment.

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