https://www.taxtmi.com/caselaws?id=773019 A reassessment notice issued after three years from the end of the relevant assessment year must have prior sanction from the authority prescribed under section 151. Here, the notice under section 148 was approved by the Principal Commissioner of Income Tax instead of the required higher authority, creating a jurisdictional defect. The reopening was therefore treated as invalid and the reassessment proceedings were void ab initio. As the notice failed on this threshold ground, the merits of the addition were not examined. en-us Wed, 11 Jun 2025 00:00:00 +0530 Tue, 17 Jun 2025 07:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773019 A reassessment notice issued after three years from the end of the relevant assessment year must have prior sanction from the authority prescribed under section 151. Here, the notice under section 148 was approved by the Principal Commissioner of Income Tax instead of the required higher authority, creating a jurisdictional defect. The reopening was therefore treated as invalid and the reassessment proceedings were void ab initio. As the notice failed on this threshold ground, the merits of the addition were not examined. Case-Laws Income Tax Wed, 11 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773019