Reassessment barred by limitation and defective approval requirements led to jurisdictional invalidity of the notice and proceedings.

Reassessment proceedings were treated as jurisdictionally invalid because the parties accepted that the action was barred by limitation, and no contrary facts were found to displace that position. The challenge also raised lack of valid approval under section 151 and non-compliance with section 151A and the CBDT notification. On the material noted, the reassessment notice and proceedings were therefore regarded as liable to be quashed, and the assessee succeeded.

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Issues: Whether the reassessment notice and the reassessment proceedings were liable to be quashed on the grounds of limitation, lack of valid approval under section 151, and non-compliance with section 151A and the CBDT notification.

Analysis: Both parties accepted that the appeal was covered by the decision of the Supreme Court in Rajeev Bansal and that the reassessment action was barred by limitation. On the material placed before it, no contrary facts were found to displace that position. The challenge to the reassessment was therefore treated as going to jurisdiction.

Conclusion: The appeal was allowed on jurisdictional grounds, and the assessee succeeded.

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