https://www.taxtmi.com/caselaws?id=467136 Reopening beyond three years required sanction by the competent higher authority; where the sanction was recorded as granted by a lower authority (PCIT) instead of the required superior authority, the sanction was treated as invalid. The court applied the statutory scheme for reopening assessments, held the proviso inserted later inapplicable to the 2022 actions, followed precedents on invalid sanctions by incorrect officers, and consequently quashed the notice under Section 148 and the order under Section 148A(d) dated 5 April 2022 in favour of the assessee. en-us Mon, 15 Apr 2024 00:00:00 +0530 Fri, 06 Mar 2026 20:54:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467136 Reopening beyond three years required sanction by the competent higher authority; where the sanction was recorded as granted by a lower authority (PCIT) instead of the required superior authority, the sanction was treated as invalid. The court applied the statutory scheme for reopening assessments, held the proviso inserted later inapplicable to the 2022 actions, followed precedents on invalid sanctions by incorrect officers, and consequently quashed the notice under Section 148 and the order under Section 148A(d) dated 5 April 2022 in favour of the assessee. Case-Laws Income Tax Mon, 15 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467136