https://www.taxtmi.com/caselaws?id=427533 Prior satisfaction of the prescribed authority under section 151 is a statutory precondition to issuing a reassessment notice under section 148; if that approval exists only after the notice, the notice is jurisdictionally defective. Section 282A and Rule 127A govern authentication of notices and documents, but they do not cure the absence of prior sanction required before the Assessing Officer assumes jurisdiction. A later unsigned or digitally signed approval cannot retrospectively validate a notice issued without the requisite authority. The reassessment proceedings founded on such notices were therefore treated as without jurisdiction, except where satisfaction and issuance were found to be simultaneous. en-us Thu, 08 Sep 2022 00:00:00 +0530 Thu, 30 Apr 2026 18:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427533 Prior satisfaction of the prescribed authority under section 151 is a statutory precondition to issuing a reassessment notice under section 148; if that approval exists only after the notice, the notice is jurisdictionally defective. Section 282A and Rule 127A govern authentication of notices and documents, but they do not cure the absence of prior sanction required before the Assessing Officer assumes jurisdiction. A later unsigned or digitally signed approval cannot retrospectively validate a notice issued without the requisite authority. The reassessment proceedings founded on such notices were therefore treated as without jurisdiction, except where satisfaction and issuance were found to be simultaneous. Case-Laws Income Tax Thu, 08 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427533