https://www.taxtmi.com/caselaws?id=789021 A reassessment notice issued beyond three years from the end of the relevant assessment year required approval from the Principal Chief Commissioner or Chief Commissioner under section 151(ii), and sanction by the Principal Commissioner was insufficient. The separate sanction requirement under section 151 could not be diluted by section 149, and the Finance Act 2023 proviso to section 151 was held prospective, so it could not cure the defect in an earlier notice. Because the reassessment was without valid jurisdictional sanction, the section 263 revisionary order lacked a lawful foundation and could not survive. en-us Tue, 24 Feb 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789021 A reassessment notice issued beyond three years from the end of the relevant assessment year required approval from the Principal Chief Commissioner or Chief Commissioner under section 151(ii), and sanction by the Principal Commissioner was insufficient. The separate sanction requirement under section 151 could not be diluted by section 149, and the Finance Act 2023 proviso to section 151 was held prospective, so it could not cure the defect in an earlier notice. Because the reassessment was without valid jurisdictional sanction, the section 263 revisionary order lacked a lawful foundation and could not survive. Case-Laws Income Tax Tue, 24 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789021