https://www.taxtmi.com/caselaws?id=786936 A notice treated as a deemed show-cause under Section 148A(b) must yield any fresh notice within the surviving period computed under Section 149 read with TOLA; issuance after that surviving period renders the notice time barred and the reassessment invalid. Where post-three-year approval is required, approval must come from the statutorily specified higher authority; approval by a lower, non-competent officer vitiates jurisdiction and any reassessment based on such defective sanction is invalid. An assessing officer lacking pecuniary or territorial jurisdiction, without a valid transfer order under Section 127, cannot initiate reassessment; such jurisdictional defect nullifies the notice and assessment. en-us Wed, 18 Feb 2026 00:00:00 +0530 Mon, 23 Feb 2026 07:38:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786936 A notice treated as a deemed show-cause under Section 148A(b) must yield any fresh notice within the surviving period computed under Section 149 read with TOLA; issuance after that surviving period renders the notice time barred and the reassessment invalid. Where post-three-year approval is required, approval must come from the statutorily specified higher authority; approval by a lower, non-competent officer vitiates jurisdiction and any reassessment based on such defective sanction is invalid. An assessing officer lacking pecuniary or territorial jurisdiction, without a valid transfer order under Section 127, cannot initiate reassessment; such jurisdictional defect nullifies the notice and assessment. Case-Laws Income Tax Wed, 18 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786936