Jurisdictional sanction for reassessment beyond three years must come from the specified authority, failing which proceedings are invalid.

Reassessment beyond three years from the end of the relevant assessment year requires prior sanction from the authority specified in section 151(ii), and approval from the Principal Commissioner of Income Tax does not satisfy that requirement. The text explains that where notice under section 148 was issued after that period, sanction had to come from the Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General, as applicable. It treats sanction by an incorrect authority as a jurisdictional defect going to the root of the proceedings. On that basis, the reassessment and consequential assessment under section 147 read with section 144B were stated to be invalid, rendering challenges to the additions academic.

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Issues: Whether the reassessment proceedings and the assessment framed under section 147 read with section 144B of the Income-tax Act, 1961 were valid where notice under section 148 had been issued beyond three years from the end of the relevant assessment year but approval had been obtained only from the Principal Commissioner of Income Tax and not from the authority specified under section 151(ii).

Analysis: For assessment year 2018-19, notice under section 148 was issued on 28.04.2022, i.e. after more than three years from the end of the relevant assessment year. In such a situation, the statute required prior approval of the Principal Chief Commissioner or Principal Director General or, where applicable, the Chief Commissioner or Director General under section 151(ii). The approval actually obtained was from the Principal Commissioner of Income Tax, which did not satisfy the statutory mandate. The absence of approval from the correct specified authority went to the root of jurisdiction. Once the reassessment was found invalid on this ground, the other challenges to the additions became academic.

Conclusion: The reassessment and the assessment order were invalid for want of proper sanction under section 151(ii) and were quashed.

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