https://www.taxtmi.com/caselaws?id=784218 Reassessment initiation under the post-2021 regime was challenged on the ground that sanction for issuing notice under s.148A(b) and the consequent order under s.148A(d) was granted by an authority not competent under s.151. Applying SC rulings holding that the "appropriate authority" requirement is mandatory and cannot be diluted, the Tribunal held that where the notice is issued beyond three years from the end of the relevant AY, approval must be accorded under s.151(ii) by the Principal Chief Commissioner. Since sanction was taken from a Principal Commissioner, the jurisdictional precondition failed; consequently, the s.148A(d) order and notice dated 28/07/2022 were quashed. en-us Tue, 09 Dec 2025 00:00:00 +0530 Wed, 31 Dec 2025 09:17:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784218 Reassessment initiation under the post-2021 regime was challenged on the ground that sanction for issuing notice under s.148A(b) and the consequent order under s.148A(d) was granted by an authority not competent under s.151. Applying SC rulings holding that the "appropriate authority" requirement is mandatory and cannot be diluted, the Tribunal held that where the notice is issued beyond three years from the end of the relevant AY, approval must be accorded under s.151(ii) by the Principal Chief Commissioner. Since sanction was taken from a Principal Commissioner, the jurisdictional precondition failed; consequently, the s.148A(d) order and notice dated 28/07/2022 were quashed. Case-Laws Income Tax Tue, 09 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784218