https://www.taxtmi.com/caselaws?id=210918 HC upheld the ITAT's order quashing the reassessment proceedings initiated under ss.147/148 on the ground of absence of mandatory sanction under s.151(1) from the competent authority. The AO had expressly sought approval only from the Commissioner, and the Additional CIT merely routed the file onward with an endorsement requesting the Commissioner's approval, without recording independent satisfaction or granting sanction. HC held that tax authorities under s.116 are distinct and one authority's satisfaction cannot substitute another's jurisdictional discretion. The defect was jurisdictional, not a curable irregularity under s.292B. Consequently, the reassessment notice and proceedings were held invalid and stood set aside. en-us Wed, 14 Sep 2011 00:00:00 +0530 Tue, 02 Dec 2025 18:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210918 HC upheld the ITAT's order quashing the reassessment proceedings initiated under ss.147/148 on the ground of absence of mandatory sanction under s.151(1) from the competent authority. The AO had expressly sought approval only from the Commissioner, and the Additional CIT merely routed the file onward with an endorsement requesting the Commissioner's approval, without recording independent satisfaction or granting sanction. HC held that tax authorities under s.116 are distinct and one authority's satisfaction cannot substitute another's jurisdictional discretion. The defect was jurisdictional, not a curable irregularity under s.292B. Consequently, the reassessment notice and proceedings were held invalid and stood set aside. Case-Laws Income Tax Wed, 14 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210918