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Reopening assessments beyond three years requires prior approval...

Validity of reopening of assessment beyond three years requires specified authority approval under section 151; notice invalidated

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Income Tax January 28, 2026 Case Laws AT
Reopening assessments beyond three years requires prior approval from the specified authority; approval must be from PCCIT or PDGIT, or if none exist, from CCIT or DGIT under the procedural mandate, and failure to obtain such specified-authority sanction renders notices issued under section 148 void for want of jurisdiction. The procedural requirements of Section 151 are mandatory and cannot be satisfied by any other officers concurrence; accordingly, a notice issued without the prescribed specified-authority approval is invalid and liable to be quashed, resulting in relief to the taxpayer.

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Acts Income Tax