Reassessment sanction under section 151(ii) must come from the specified higher authority; approval by a lower authority invalidates the notice.

Reassessment initiated after three years from the end of the relevant assessment year requires approval under section 151(ii) from the specified higher authority. Where sanction for issue of notice under section 148 was obtained from the Principal Commissioner instead of the Principal Chief Commissioner, the statutory approval requirement was not met, and the notice could not sustain the reassessment. Binding jurisdictional precedent was followed to hold that approval by a lower authority is ineffective. The reassessment proceedings were quashed on this jurisdictional defect, and the merits of the addition were not examined.

---

---

Issues: Whether reassessment initiated beyond three years from the end of the relevant assessment year was valid when approval for issuance of notice under section 148 was obtained from the Principal Commissioner instead of the Principal Chief Commissioner under section 151(ii) of the Income-tax Act, 1961.

Analysis: The notice under section 148 was issued for assessment year 2017-18 after expiry of three years from the end of the relevant assessment year, so the approval requirement under section 151(ii) applied. The sanction obtained from the Principal Commissioner did not satisfy the statutory mandate requiring approval from the specified higher authority. The Tribunal followed binding jurisdictional precedent holding that such approval is mandatory and that approval by a lower authority renders the reassessment invalid. Since the reassessment was quashed on this jurisdictional issue, the merits of the addition were not examined.

Conclusion: The reassessment proceedings and notice under section 148 were held invalid and quashed, in favour of the assessee.

---