https://www.taxtmi.com/caselaws?id=465604 Where a notice under s.148 was issued for AY 2016-17 after expiry of three years, the dominant issue was whether the reopening was vitiated for want of sanction from the correct "specified authority" under s.151(ii). Applying SC jurisprudence and consistent Tribunal/HC rulings that, beyond three years, prior approval must be of the Pr. CCIT (and not the Pr. CIT), the ITAT held that sanction by an ineligible authority is a jurisdictional defect rendering the notice void ab initio. The s.148 notice was quashed and the consequential reassessment order under s.147 r/w s.144B was set aside; the appeal was allowed. en-us Wed, 09 Jul 2025 00:00:00 +0530 Fri, 02 Jan 2026 07:07:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465604 Where a notice under s.148 was issued for AY 2016-17 after expiry of three years, the dominant issue was whether the reopening was vitiated for want of sanction from the correct "specified authority" under s.151(ii). Applying SC jurisprudence and consistent Tribunal/HC rulings that, beyond three years, prior approval must be of the Pr. CCIT (and not the Pr. CIT), the ITAT held that sanction by an ineligible authority is a jurisdictional defect rendering the notice void ab initio. The s.148 notice was quashed and the consequential reassessment order under s.147 r/w s.144B was set aside; the appeal was allowed. Case-Laws Income Tax Wed, 09 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465604