Reassessment sanction under the extended limitation regime...

Reassessment sanction under the extended limitation regime depended on the date by which the three-year period from the end of the relevant assessment year expired. Where that period expired during the TOLA-covered period, the authority under section 151(i) could grant sanction only until 30 June 2021. Orders under section 148A(d) and consequential reassessment notices issued later required sanction from the competent specified authority under section 151(ii). Approval by the Principal Commissioner under section 151(i) after that date invalidated jurisdiction to revive reassessment proceedings, resulting in the order being quashed.