https://www.taxtmi.com/caselaws?id=774177 Section 151 (as applicable after 01/04/2021) requires that reopenings under section 148 issued after the three year period must be sanctioned by the Principal Chief Commissioner/Chief Commissioner or other specified higher authority; a sanction by the Principal Commissioner of Income Tax is not the prescribed authority for such post three year notices. Because the final notice dated 06/04/2022 related to A.Y.2018 19 was issued after three years and bore sanction only from the PCIT, the notice and consequent reassessment proceedings were held invalid and quashed; the appeal succeeded in favour of the assessee. en-us Thu, 22 May 2025 00:00:00 +0530 Sat, 21 Mar 2026 12:00:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774177 Section 151 (as applicable after 01/04/2021) requires that reopenings under section 148 issued after the three year period must be sanctioned by the Principal Chief Commissioner/Chief Commissioner or other specified higher authority; a sanction by the Principal Commissioner of Income Tax is not the prescribed authority for such post three year notices. Because the final notice dated 06/04/2022 related to A.Y.2018 19 was issued after three years and bore sanction only from the PCIT, the notice and consequent reassessment proceedings were held invalid and quashed; the appeal succeeded in favour of the assessee. Case-Laws Income Tax Thu, 22 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774177