Reassessment limitation and prior sanction requirements rendered the reopening invalid and the consequential assessment unsustainable.

Under the new reassessment regime, the Tribunal held that the reassessment notice and consequential order were jurisdictionally defective because the escaped income did not meet the threshold for extended limitation and the required prior approval under section 151 was not obtained. The statutory conditions governing limitation and sanction were therefore not satisfied, rendering the reopening invalid. As the reassessment itself was unsustainable, the consequential assessment order could not survive and was quashed as bad in law.

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Issues: Whether the reassessment notice and consequential assessment order were invalid for non-compliance with the time limit and approval requirements under the reassessment provisions of the Income-tax Act, 1961.

Analysis: The notice under section 148 was issued under the new reassessment regime after the relevant assessment year. The Tribunal found that the escaped income did not exceed the threshold attracting the extended limitation, and that the notice and the order under section 148A(d) and section 148 required prior approval from the competent authority under section 151. Since the statutory conditions governing limitation and sanction were not satisfied, the reassessment proceedings were held to be jurisdictionally defective. Once the reassessment itself was invalid, the consequential assessment could not survive.

Conclusion: The reassessment notice and the assessment order were quashed as bad in law, and the reopening was held invalid.

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