Mandatory approval for delayed reassessment notices is jurisdictional; approval by an incorrectly designated authority invalidates the notice.

Reassessment notices issued beyond three years from the end of the relevant assessment year require prior approval from the authority specified under Section 151(ii). Approval by a Principal Commissioner alone does not satisfy this mandatory jurisdictional requirement where approval from the Principal Chief Commissioner or other specified authority is required. A notice issued without such valid approval is without jurisdiction and must be invalidated. The stated analysis confirms that the reassessment notice was invalid for failure to obtain approval from the appropriate authority.

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Issues: Whether a notice for reassessment issued beyond three years from the end of the relevant assessment year was valid without prior approval of the Principal Chief Commissioner or other authority specified for such cases.

Analysis: A reassessment notice issued beyond three years required approval from the authority specified under Section 151(ii). Approval obtained only from the Principal Commissioner did not meet that mandatory jurisdictional requirement. The reassessment initiation was therefore without jurisdiction, and the Tribunal correctly invalidated the notice.

Conclusion: The reassessment notice was invalid for want of approval from the appropriate specified authority; the issue was decided in favour of the assessee.

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