https://www.taxtmi.com/caselaws?id=465354 The dominant issue was whether reassessment reopening under s.147 was valid when sanction for issuing notice under s.148 was granted by an allegedly non-competent authority under s.151, and whether s.3 of TOLA could cure that defect. Relying on its earlier precedent, the HC held that "sanction" in s.3 of TOLA extends only to statutory timelines for approval and does not validate a sanction granted by an officer lacking jurisdiction under s.151. Since the impugned s.148 notices rested on approval from a non-competent officer, the reassessment action was unsustainable, and the notices were quashed. en-us Mon, 10 Feb 2025 00:00:00 +0530 Wed, 17 Dec 2025 21:52:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465354 The dominant issue was whether reassessment reopening under s.147 was valid when sanction for issuing notice under s.148 was granted by an allegedly non-competent authority under s.151, and whether s.3 of TOLA could cure that defect. Relying on its earlier precedent, the HC held that "sanction" in s.3 of TOLA extends only to statutory timelines for approval and does not validate a sanction granted by an officer lacking jurisdiction under s.151. Since the impugned s.148 notices rested on approval from a non-competent officer, the reassessment action was unsustainable, and the notices were quashed. Case-Laws Income Tax Mon, 10 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465354