Reassessment sanction requirement under section 151 controls validity, and a dependent revision order falls when jurisdiction is absent.

A reassessment notice issued beyond three years from the end of the relevant assessment year required approval from the Principal Chief Commissioner or Chief Commissioner under section 151(ii), and sanction by the Principal Commissioner was insufficient. The separate sanction requirement under section 151 could not be diluted by section 149, and the Finance Act 2023 proviso to section 151 was held prospective, so it could not cure the defect in an earlier notice. Because the reassessment was without valid jurisdictional sanction, the section 263 revisionary order lacked a lawful foundation and could not survive.

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Issues: (i) Whether the notice issued under section 148 was invalid for want of sanction from the correct specified authority under section 151. (ii) Whether the section 263 revisionary order could survive when the reassessment proceedings were void for lack of valid jurisdictional sanction.

Issue (i): Whether the notice issued under section 148 was invalid for want of sanction from the correct specified authority under section 151.

Analysis: The notice under section 148 was issued beyond three years from the end of the relevant assessment year. For such cases, section 151(ii) required approval from the Principal Chief Commissioner or Chief Commissioner, and not from the Principal Commissioner. The limitation provisions in section 149 could not be used to dilute the separate sanction requirement under section 151. The proviso inserted in section 151 by the Finance Act, 2023 was held to be prospective and could not validate a prior notice issued on approval from the wrong authority.

Conclusion: The notice under section 148 was invalid in law for want of sanction from the correct specified authority.

Issue (ii): Whether the section 263 revisionary order could survive when the reassessment proceedings were void for lack of valid jurisdictional sanction.

Analysis: Once the reassessment initiation itself was found to be without jurisdiction, the foundation for the revisionary exercise ceased to exist. A revision under section 263 cannot independently stand where the underlying reassessment proceeding is legally unsustainable.

Conclusion: The section 263 order could not survive and was set aside.

Final Conclusion: The assessee succeeded because the reassessment notice was held invalid for want of proper approval, and the revisionary order based on that defective proceeding was annulled.

Ratio Decidendi: Where reassessment is initiated beyond three years, approval must be obtained from the authority specified in section 151(ii), and a revisionary order cannot survive if the underlying reassessment proceeding is void for want of such jurisdictional sanction.

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