Reassessment jurisdiction fails when approval comes from the wrong authority, rendering the reassessment unsustainable.

Reassessment jurisdiction failed where approval was not obtained from the prescribed specified authority under the reassessment scheme applicable to the relevant assessment year. For AY 2017-18, the record showed approval under section 151 from the Principal Commissioner of Income Tax, but the applicable scheme required approval from the authority prescribed for that year. Because the approval defect went to the root of jurisdiction, the reassessment proceedings and the consequent assessment were quashed.

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Issues: Whether reassessment proceedings and the consequent assessment were vitiated for want of approval from the prescribed specified authority under the reassessment scheme applicable to the relevant assessment year.

Analysis: For assessment year 2017-18, the record showed approval under section 151 of the Income-tax Act, 1961 from the Principal Commissioner of Income Tax. On the admitted facts, the approval required for the reassessment action was that of the prescribed authority for the relevant assessment year. The defect went to the root of the reassessment jurisdiction, and the reassessment could not be sustained.

Conclusion: The reassessment proceedings and the consequent assessment were quashed, and the assessee succeeded.

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