https://www.taxtmi.com/caselaws?id=465583 The dominant issue was whether reassessment initiated without prior sanction under s.151 was valid, and whether the defect could be cured by s.292B. The ITAT held that s.151(2) uses the mandatory expression "unless," making the Joint Commissioner's satisfaction a jurisdictional precondition where the AO is below that rank; absence of such sanction is an inherent defect, not a procedural irregularity. Applying strict interpretation of taxing statutes as affirmed by the SC, the tribunal ruled that s.292B cannot validate a notice issued without mandatory approval, rendering the reopening non est in law and therefore invalid. en-us Fri, 17 Sep 2021 00:00:00 +0530 Wed, 31 Dec 2025 20:13:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465583 The dominant issue was whether reassessment initiated without prior sanction under s.151 was valid, and whether the defect could be cured by s.292B. The ITAT held that s.151(2) uses the mandatory expression "unless," making the Joint Commissioner's satisfaction a jurisdictional precondition where the AO is below that rank; absence of such sanction is an inherent defect, not a procedural irregularity. Applying strict interpretation of taxing statutes as affirmed by the SC, the tribunal ruled that s.292B cannot validate a notice issued without mandatory approval, rendering the reopening non est in law and therefore invalid. Case-Laws Income Tax Fri, 17 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465583