https://www.taxtmi.com/caselaws?id=787793 Sanction to reopen was required to reflect an objective application of mind by the sanctioning authority; reliance on a factually erroneous premise (that the assessee was a non filer) meant the recorded satisfaction was vitiated and therefore jurisdictionally defective. The tribunal applied the principle that sanction is a mandatory prerequisite to valid issuance of a reopening notice and must be founded on correct facts; where irrelevant or incorrect facts overbear satisfaction, the sanction and consequent notice and reassessment lose validity. On that basis the reopening notice and reassessment order were quashed and the appeal allowed for the assessee. en-us Thu, 05 Mar 2026 00:00:00 +0530 Thu, 12 Mar 2026 08:33:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787793 Sanction to reopen was required to reflect an objective application of mind by the sanctioning authority; reliance on a factually erroneous premise (that the assessee was a non filer) meant the recorded satisfaction was vitiated and therefore jurisdictionally defective. The tribunal applied the principle that sanction is a mandatory prerequisite to valid issuance of a reopening notice and must be founded on correct facts; where irrelevant or incorrect facts overbear satisfaction, the sanction and consequent notice and reassessment lose validity. On that basis the reopening notice and reassessment order were quashed and the appeal allowed for the assessee. Case-Laws Income Tax Thu, 05 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787793