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Reassessment after the applicable three-year period requires...
Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framework.
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Reassessment after the applicable three-year period requires sanction from the authority specified by the law governing the elapsed period. Time-exclusion and adjustment provisos to the reassessment limitation provision did not alter the relevant period under clause (a), and the later proviso to section 151 changed a substantive jurisdictional safeguard prospectively rather than validating prior defective approval. Sanction by the Principal Commissioner where approval by the higher specified authority was required rendered the reassessment notice and order jurisdictionally invalid. Third-party survey material, including loose papers and statements, could not support reassessment without a prima facie live link to the taxpayer or alleged escaped income; the notice and order were quashed.
Reassessment after the applicable three-year period requires sanction from the authority specified by the law governing the elapsed period. Time-exclusion and adjustment provisos to the reassessment limitation provision did not alter the relevant period under clause (a), and the later proviso to section 151 changed a substantive jurisdictional safeguard prospectively rather than validating prior defective approval. Sanction by the Principal Commissioner where approval by the higher specified authority was required rendered the reassessment notice and order jurisdictionally invalid. Third-party survey material, including loose papers and statements, could not support reassessment without a prima facie live link to the taxpayer or alleged escaped income; the notice and order were quashed.
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