Reassessment notice invalid without proper statutory approval, and all consequential proceedings were quashed.

A reassessment notice issued after expiry of three years from the end of the relevant assessment year requires approval from the authority prescribed under section 151(ii), and sanction by the PCIT does not satisfy that jurisdictional safeguard. Because approval was granted by an not specified by the statute, the assumption of jurisdiction to issue the section 148 notice was vitiated, and all consequential reassessment proceedings were quashed in favour of the assessee.

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Issues: Whether the reassessment notice issued under section 148 was invalid for want of approval from the competent authority under section 151(ii), and whether the reassessment proceedings based on such notice were liable to be quashed.

Analysis: The approval recorded for the notice and the order under section 148A(d) was by the PCIT, whereas for a notice issued after expiry of three years from the end of the relevant assessment year, the statute required approval from the specified higher authority. Sanction under section 151(ii) is a jurisdictional safeguard and not a procedural formality. Once approval is granted by an authority not prescribed by the statute, the very assumption of jurisdiction to issue the notice under section 148 is vitiated, and all consequential proceedings cannot survive.

Conclusion: The reassessment notice was invalid for want of proper approval under section 151(ii), and the reassessment proceedings were quashed, in favour of the assessee.

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