Competent approval for delayed reassessment notices was mandatory; approval by an unauthorised authority invalidated the notice and assessment.

Reassessment notices for assessment year 2016-17 issued beyond three years required approval from the prescribed senior authority: the Principal Chief Commissioner or Deputy Director General, or, in their absence, the Chief Commissioner or Director General. Approval by the Principal Commissioner of Income-tax did not meet this jurisdictional requirement. Consequently, the reassessment notice was invalid and the consequential assessment order was quashed.

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Issues: Whether the reassessment notice for assessment year 2016-17, issued after three years upon approval by the Principal Commissioner of Income-tax, was validly sanctioned by the competent authority.

Analysis: For reassessment notices concerning assessment year 2016-17 issued beyond three years, the prescribed approving authority was the Principal Chief Commissioner or Deputy Director General; in their absence, the Chief Commissioner or Director General. Approval granted by the Principal Commissioner of Income-tax did not satisfy this jurisdictional requirement.

Conclusion: The reassessment notice was invalid for want of approval from the competent authority, and the consequential assessment order was quashed.

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