Mandatory approval for delayed reassessment invalidates the entire reassessment where sanction comes from the wrong authority.

Reassessment initiated after more than three years from the end of the relevant assessment year required prior approval from the statutorily prescribed authority. Because the sanction on record was not from the designated competent authority, the mandatory condition for valid reassessment was not satisfied. The absence of proper approval vitiated the reassessment machinery at the threshold, and the consequential assessment order could not be sustained, rendering it void in favour of the assessee.

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Issues: Whether the reassessment proceedings were vitiated for want of approval from the competent authority under section 151 of the Income-tax Act, 1961, resulting in the assessment being void.

Analysis: The reassessment notice was issued after more than three years from the end of the relevant assessment year. In such a case, approval had to be obtained from the authority prescribed under the statutory framework governing reassessment sanction. The approval on record was not from the designated authority. Once the mandatory statutory sanction was absent, the reassessment machinery itself was not validly set in motion and the assessment order that followed could not be sustained.

Conclusion: The reassessment proceedings were invalid and the assessment order was void, in favour of the assessee.

Ratio Decidendi: Where reassessment is initiated beyond the prescribed period and the statute mandates approval from a specified authority, absence of such approval vitiates the reassessment and renders the consequential assessment unsustainable.

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