Reassessment notice invalid without approval from the specified authority, making the resulting assessment unsustainable.

Reassessment notice issued under section 148 was jurisdictionally invalid because approval was obtained from the wrong specified authority under section 151(ii), which required sanction from the Principal Chief Commissioner rather than the Principal Commissioner. Without fulfillment of that statutory precondition, reassessment jurisdiction did not validly arise, and the consequent assessment could not survive. The notice was therefore bad in law and the assessment was quashed in favour of the assessee.

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Issues: Whether the notice issued under section 148 was valid when approval was obtained from the wrong specified authority under section 151, and whether the reassessment and consequent assessment could survive.

Analysis: The notice for reassessment was issued beyond the period discussed under section 149(1)(a) and, more importantly, the approval recorded for issuance of notice was by the Principal Commissioner of Income Tax whereas the governing approval requirement under section 151(ii) was found to require sanction by the Principal Chief Commissioner of Income Tax. Since the statutory precondition for assumption of reassessment jurisdiction was not fulfilled, the notice was treated as jurisdictionally invalid. The reassessment was therefore unsustainable.

Conclusion: The notice under section 148 was held bad in law and the consequential assessment was quashed in favour of the assessee.

Ratio Decidendi: Where reassessment notice is issued without approval from the specified authority mandated by section 151(ii), the notice is void and the resulting assessment cannot stand.

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