Limitation and reassessment jurisdiction: bona fide delay was condoned, and Section 151 approval had to be examined first.

Limitation should not be applied rigidly where the explanation shows a bona fide impediment; the death of the assessee's authorised representative and the shift to a faceless regime were treated as sufficient cause for condoning a 430-day delay in filing the appeal. A challenge to reassessment for lack of proper approval under Section 151 was treated as a jurisdictional objection going to the root of the proceeding, and it had to be decided as a preliminary issue before other matters. The impugned order was set aside, the delay was condoned, and the matter was remitted for fresh adjudication with jurisdiction to be determined first.

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Issues: (i) Whether a delay of 430 days in filing the appeal before the Tribunal ought to be condoned on the basis of sufficient cause arising from the death of the assessee's authorised representative and the transition to a faceless regime. (ii) Whether the reassessment proceedings were vitiated for want of proper approval under Section 151 of the Income-tax Act, 1961, warranting examination of jurisdiction as a preliminary issue.

Issue (i): Whether a delay of 430 days in filing the appeal before the Tribunal ought to be condoned on the basis of sufficient cause arising from the death of the assessee's authorised representative and the transition to a faceless regime.

Analysis: The delay was approached through the settled principle that limitation rules should not be applied so rigidly as to defeat substantial justice where the explanation discloses a genuine inability to act within time. The death of the person handling the assessee's tax affairs was treated as a sufficient and credible cause in the factual setting of a faceless assessment process, and the refusal to condone delay was viewed as overly technical.

Conclusion: The delay was required to be condoned.

Issue (ii): Whether the reassessment proceedings were vitiated for want of proper approval under Section 151 of the Income-tax Act, 1961, warranting examination of jurisdiction as a preliminary issue.

Analysis: A challenge going to the statutory competence for reopening assessment was treated as a jurisdictional objection striking at the root of the proceeding. The Court held that such a defect could not be ignored merely because the Tribunal had dismissed the appeal on limitation, and that the validity of the sanction under Section 151 had to be decided before anything else.

Conclusion: The jurisdictional challenge under Section 151 had to be adjudicated as a preliminary issue.

Final Conclusion: The impugned order was set aside, the delay was condoned, and the matter was sent back for fresh adjudication on merits with a direction to decide jurisdiction first.

Ratio Decidendi: Where the explanation for delay discloses a bona fide impediment and the appeal raises a jurisdictional challenge that may render the assessment void, limitation should not be used to defeat adjudication on merits, and the statutory validity of reopening must be determined at the threshold.

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