https://www.taxtmi.com/caselaws?id=785952 Reopening of assessment by issue of notice beyond three years required prior approval from the specified authority under Section 151; absence of sanction from the Principal Chief Commissioner or equivalent rendered the notice invalid, following the High Court precedent in Communist Party of India (M). The determination of which senior officer must grant approval depends on whether the section 148 notice was issued after the threeyear limitation period or within it; where issued after three years the higher specified authority's sanction is mandatory. Consequence: the impugned reopening notice was set aside and decision favoured the assessee. en-us Tue, 20 Jan 2026 00:00:00 +0530 Tue, 03 Feb 2026 08:39:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785952 Reopening of assessment by issue of notice beyond three years required prior approval from the specified authority under Section 151; absence of sanction from the Principal Chief Commissioner or equivalent rendered the notice invalid, following the High Court precedent in Communist Party of India (M). The determination of which senior officer must grant approval depends on whether the section 148 notice was issued after the threeyear limitation period or within it; where issued after three years the higher specified authority's sanction is mandatory. Consequence: the impugned reopening notice was set aside and decision favoured the assessee. Case-Laws Income Tax Tue, 20 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785952