https://www.taxtmi.com/caselaws?id=467133 Sanction for reassessment notices issued more than three years after the relevant assessment year must be granted by the Principal Chief Commissioner or an equivalent higher authority under Section 151(ii). For an April 2022 notice relating to assessment year 2018-19, the later Finance Act 2023 proviso permitting adjustment of the three-year period for exclusions or extensions under Section 149(1) did not apply. Sanction by the CIT or PCIT was therefore insufficient, invalidating the notice under Section 148 and consequential reassessment under Section 147. The resulting reassessment order was quashed, without examination of the additions on merits. en-us Wed, 15 Oct 2025 00:00:00 +0530 Fri, 18 Sep 2026 15:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467133 Sanction for reassessment notices issued more than three years after the relevant assessment year must be granted by the Principal Chief Commissioner or an equivalent higher authority under Section 151(ii). For an April 2022 notice relating to assessment year 2018-19, the later Finance Act 2023 proviso permitting adjustment of the three-year period for exclusions or extensions under Section 149(1) did not apply. Sanction by the CIT or PCIT was therefore insufficient, invalidating the notice under Section 148 and consequential reassessment under Section 147. The resulting reassessment order was quashed, without examination of the additions on merits. Case-Laws Income Tax Wed, 15 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467133