Mandatory sanction under reassessment law vitiates reopening when approval comes from the wrong authority after three years.

Reassessment initiated after three years from the end of the relevant assessment year requires approval from the sanctioning authority prescribed under section 151 for that extended period. Because approval was obtained from the Principal Commissioner instead of the higher authority mandated by the substituted reassessment regime, the jurisdictional condition for reopening was not met. The reassessment notice and the assessment founded on it were therefore invalid and quashed in favour of the assessee, leaving the remaining grounds academic.

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Issues: Whether the reassessment notice and consequent assessment were valid when approval under section 151 was obtained from the Principal Commissioner instead of the higher authority required after expiry of three years from the end of the relevant assessment year.

Analysis: The appeal turned on the legality of reassessment for assessment year 2017-18 under the substituted reassessment regime. Since the notice under section 148 was issued after three years from the end of the relevant assessment year, approval had to be obtained from the authority specified in section 151 for such cases. The approval having been granted by the Principal Commissioner, the jurisdictional condition for reopening was not satisfied.

Conclusion: The reassessment initiation was invalid and the assessment order founded on such notice was quashed, in favour of the assessee.

Final Conclusion: The appeal succeeded on the jurisdictional challenge to reassessment, and the remaining grounds were left open as academic.

Ratio Decidendi: Where reassessment is initiated beyond three years from the end of the relevant assessment year, compliance with the statutorily prescribed sanctioning authority under section 151 is mandatory, and approval by an incompetent authority vitiates the reopening.

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