https://www.taxtmi.com/caselaws?id=460566 For reassessment proceedings initiated beyond three years from the end of the relevant assessment year, sanction had to be accorded by the authority prescribed under section 151(ii) of the Income-tax Act, 1961. Where sanction for the notice under section 148 and the order under section 148A(d) was granted by the Principal Commissioner instead of the Principal Chief Commissioner, the statutory precondition was not met. The proviso to section 151, inserted with effect from 1 April 2023, was held inapplicable to the reassessment for assessment year 2017-18. The invalid sanction vitiated both the notice and the consequential order, which were quashed and set aside. en-us Mon, 29 Apr 2024 00:00:00 +0530 Fri, 31 Jan 2025 18:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460566 For reassessment proceedings initiated beyond three years from the end of the relevant assessment year, sanction had to be accorded by the authority prescribed under section 151(ii) of the Income-tax Act, 1961. Where sanction for the notice under section 148 and the order under section 148A(d) was granted by the Principal Commissioner instead of the Principal Chief Commissioner, the statutory precondition was not met. The proviso to section 151, inserted with effect from 1 April 2023, was held inapplicable to the reassessment for assessment year 2017-18. The invalid sanction vitiated both the notice and the consequential order, which were quashed and set aside. Case-Laws Income Tax Mon, 29 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460566