https://www.taxtmi.com/caselaws?id=790230 Reassessment beyond three years from the end of the relevant assessment year required prior approval from the specified higher authority under Section 151(ii) of the Income-tax Act. Although the relaxation under TOLA extended the time for obtaining approval in the relevant category of cases up to 30 June 2021, it did not remove the requirement that sanction be granted by the correct statutory authority. Where approval was obtained from the Principal Commissioner instead of the authority mandated by Section 151(ii), the jurisdictional precondition for reopening was not met. The notice under Section 148 and the consequential reassessment proceedings were therefore invalid. en-us Mon, 16 Feb 2026 00:00:00 +0530 Tue, 21 Apr 2026 16:53:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790230 Reassessment beyond three years from the end of the relevant assessment year required prior approval from the specified higher authority under Section 151(ii) of the Income-tax Act. Although the relaxation under TOLA extended the time for obtaining approval in the relevant category of cases up to 30 June 2021, it did not remove the requirement that sanction be granted by the correct statutory authority. Where approval was obtained from the Principal Commissioner instead of the authority mandated by Section 151(ii), the jurisdictional precondition for reopening was not met. The notice under Section 148 and the consequential reassessment proceedings were therefore invalid. Case-Laws Income Tax Mon, 16 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790230