https://www.taxtmi.com/caselaws?id=789767 Compliance with the statutory approval requirement under section 151 is a jurisdictional condition precedent to reassessment under sections 148 and 148A(d). Where more than three years had elapsed from the end of the relevant assessment year, approval had to be obtained from the competent higher specified authority before issuance of notice under section 148. As that approval was not obtained, even though sanction for the section 148A(d) order was taken from the Principal Commissioner, the reassessment notice and all consequent proceedings were invalid and liable to be quashed. The reassessment was therefore annulled on jurisdictional grounds, and the Revenue's merits grounds became infructuous. en-us Fri, 10 Apr 2026 00:00:00 +0530 Tue, 14 Apr 2026 08:03:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789767 Compliance with the statutory approval requirement under section 151 is a jurisdictional condition precedent to reassessment under sections 148 and 148A(d). Where more than three years had elapsed from the end of the relevant assessment year, approval had to be obtained from the competent higher specified authority before issuance of notice under section 148. As that approval was not obtained, even though sanction for the section 148A(d) order was taken from the Principal Commissioner, the reassessment notice and all consequent proceedings were invalid and liable to be quashed. The reassessment was therefore annulled on jurisdictional grounds, and the Revenue's merits grounds became infructuous. Case-Laws Income Tax Fri, 10 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789767