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    <title>2025 (12) TMI 160 - ITAT DELHI</title>
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    <description>Approval from the statutorily designated specified authority is a jurisdictional precondition for reassessment under the new regime. Where the notice under section 148 and the order under section 148A(d) were issued after more than three years from the end of the assessment year, sanction had to come from the higher authority required by section 151; approval obtained only from the Principal Commissioner was insufficient, rendering the reassessment void ab initio. The Tribunal also held that the reassessment was barred by limitation, as the notice was not issued within the surviving time available after the assessee&#039;s response and the extended timeline could not sustain the proceedings. Both findings were in favour of the assessee.</description>
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    <pubDate>Wed, 20 Aug 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 160 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782620</link>
      <description>Approval from the statutorily designated specified authority is a jurisdictional precondition for reassessment under the new regime. Where the notice under section 148 and the order under section 148A(d) were issued after more than three years from the end of the assessment year, sanction had to come from the higher authority required by section 151; approval obtained only from the Principal Commissioner was insufficient, rendering the reassessment void ab initio. The Tribunal also held that the reassessment was barred by limitation, as the notice was not issued within the surviving time available after the assessee&#039;s response and the extended timeline could not sustain the proceedings. Both findings were in favour of the assessee.</description>
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