https://www.taxtmi.com/caselaws?id=785795 Reopening an assessment hinges on prior sanction by the competent authority designated under the substituted sanction regime; where more than three years have elapsed from the end of the relevant assessment year the higher specified authority must grant approval, and lower-authority sanction is jurisdictionally ineffective. The notice issued after expiry of three years was approved by the lower authority rather than the higher authority required for that period, which vitiates jurisdiction to issue the Section 148 notice and renders the consequent reassessment and penalty orders invalid and therefore quashed in favour of the assessee. en-us Mon, 19 Jan 2026 00:00:00 +0530 Sat, 31 Jan 2026 08:55:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785795 Reopening an assessment hinges on prior sanction by the competent authority designated under the substituted sanction regime; where more than three years have elapsed from the end of the relevant assessment year the higher specified authority must grant approval, and lower-authority sanction is jurisdictionally ineffective. The notice issued after expiry of three years was approved by the lower authority rather than the higher authority required for that period, which vitiates jurisdiction to issue the Section 148 notice and renders the consequent reassessment and penalty orders invalid and therefore quashed in favour of the assessee. Case-Laws Income Tax Mon, 19 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785795