https://www.taxtmi.com/caselaws?id=788982 A jurisdictional objection to reopening can be raised at a later appellate stage even if it was not pressed before the first appellate authority, because a defect affecting jurisdiction cannot be waived or cured by consent, acquiescence or abandonment. The reopening was also held invalid because the order under section 148A(d) and the consequential notice under section 148 were issued after three years from the end of the assessment year, requiring approval of the higher specified authority under section 151(ii). Approval by the Principal Commissioner was insufficient, so the sanction was not valid and the reassessment proceedings were void ab initio. en-us Mon, 30 Mar 2026 00:00:00 +0530 Wed, 01 Apr 2026 07:51:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788982 A jurisdictional objection to reopening can be raised at a later appellate stage even if it was not pressed before the first appellate authority, because a defect affecting jurisdiction cannot be waived or cured by consent, acquiescence or abandonment. The reopening was also held invalid because the order under section 148A(d) and the consequential notice under section 148 were issued after three years from the end of the assessment year, requiring approval of the higher specified authority under section 151(ii). Approval by the Principal Commissioner was insufficient, so the sanction was not valid and the reassessment proceedings were void ab initio. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788982