https://www.taxtmi.com/caselaws?id=787571 Sanction for reassessment proceedings initiated after three years from the end of the relevant assessment year had to be granted by the authority specified under Section 151(ii) before its amendment effective 1 April 2023. The later-inserted proviso does not retrospectively validate sanctions granted by an authority not then specified. Sections 149 and 151 operate independently, so limitation extensions under Section 149 cannot enlarge the sanctioning authority under Section 151 for the pre-amendment period. Sanction by an unauthorised authority creates a jurisdictional defect, invalidating the Section 148 notice, Section 148A(d) order and consequential reassessment proceedings; merits issues consequently do not survive. en-us Thu, 05 Mar 2026 00:00:00 +0530 Mon, 09 Mar 2026 07:53:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787571 Sanction for reassessment proceedings initiated after three years from the end of the relevant assessment year had to be granted by the authority specified under Section 151(ii) before its amendment effective 1 April 2023. The later-inserted proviso does not retrospectively validate sanctions granted by an authority not then specified. Sections 149 and 151 operate independently, so limitation extensions under Section 149 cannot enlarge the sanctioning authority under Section 151 for the pre-amendment period. Sanction by an unauthorised authority creates a jurisdictional defect, invalidating the Section 148 notice, Section 148A(d) order and consequential reassessment proceedings; merits issues consequently do not survive. Case-Laws Income Tax Thu, 05 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787571