Jurisdictional sanction for reassessment reopening must come from the competent authority; incorrect approval vitiates reassessment.

Reassessment initiated beyond three years required prior approval from the higher authority specified under the Income-tax Act. The record showed inconsistency between the sanction reflected in the order under section 148A(d) and the notice under section 148, and the approval was not shown to have been granted by the competent authority. Because valid sanction by the prescribed authority is a jurisdictional precondition for reopening, approval from an incorrect authority rendered the reassessment invalid. The reopening and consequent reassessment proceedings were quashed in favour of the assessee.

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Issues: Whether the reassessment proceedings were vitiated because approval for issuance of notice under section 148 was obtained from an authority other than the competent authority prescribed under section 151 of the Income-tax Act, 1961.

Analysis: The reassessment for the relevant assessment year had been initiated beyond three years from the end of the assessment year, and therefore the approval contemplated by section 151 had to be obtained from the specified higher authority. The record showed inconsistency in the sanction noted in the order under section 148A(d) and in the notice under section 148, and the approval was not traced to the competent authority required by law. Since sanction by the proper authority is a jurisdictional precondition for valid reopening, approval by an incorrect authority vitiates the reassessment.

Conclusion: The reopening and consequent reassessment proceedings were invalid and were quashed, in favour of the assessee.

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