SC affirms invalid income tax reassessment for AY 2016-17 due to wrong Section 151 sanction, Section 147

SC upheld the HC's decision quashing the reassessment proceedings for AY 2016-2017 under section 147. The HC had held that the mandatory prior approval under section 151 was obtained under clause (i) instead of clause (ii), which was the applicable provision for the case, rendering the sanction legally invalid. Consequently, the notice issued under section 148 and the ensuing reassessment were held without jurisdiction. Finding no error in the HC's reasoning, SC dismissed the revenue's special leave petition and affirmed the quashing of the reassessment.

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The Supreme Court, exercising its jurisdiction under Article 136, declined to interfere with the judgment of the High Court. After hearing counsel for both sides and examining the record, the Court held that it found "no good ground to interfere with the impugned order passed by the High Court." Consequently, the Special Leave Petition was dismissed. The Court did not enter into a detailed discussion of the merits or elaborate on the High Court's reasoning, implicitly affirming that no error warranting interference in special leave jurisdiction was made out. All pending applications were also disposed of.

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