Statutory approval by the correct specified authority is a jurisdictional for reopening assessments; invalid sanction vitiates reassessment.

For reopening under the post-1 April 2021 regime, approval under section 151 must come from the specified authority designated by the statute; where notice under section 148 is issued after more than three years from the end of the relevant assessment year, that authority is the Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General, as applicable. Approval granted by the Principal Commissioner does not satisfy this jurisdictional precondition. Non-compliance with section 151 therefore vitiates the reopening and renders the reassessment unsustainable.

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Issues: Whether reassessment proceedings were valid where approval for reopening was granted by the Principal Commissioner of Income Tax instead of the Principal Chief Commissioner of Income Tax after the amendment to the approval regime under section 151 of the Income-tax Act, 1961, and whether the resultant reassessment was liable to be quashed.

Analysis: The reopening fell within the post-1 April 2021 regime, under which the specified authority for a notice issued after more than three years from the end of the relevant assessment year is the Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General, as applicable. The approval granted by the Principal Commissioner did not satisfy the statutory requirement. The approval from the correct specified authority is a jurisdictional precondition for issuance of notice under section 148, and non-compliance with section 151 vitiates the reopening. The Tribunal relied on the Supreme Court and other High Court decisions applying the same principle and treated the defect as fatal to the reassessment.

Conclusion: The reopening was invalid for want of approval by the correct specified authority, and the reassessment proceedings were quashed.

Final Conclusion: The assessee succeeded because the reassessment was held unsustainable for absence of valid statutory sanction, resulting in annulment of the assessment action.

Ratio Decidendi: Where the statute prescribes approval by a specific authority as a condition precedent for reopening an assessment, sanction by an unauthorised authority renders the reassessment jurisdictionally invalid.

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