https://www.taxtmi.com/caselaws?id=790555 Reassessment approval under section 151 must be based on a clear and consistent view of the alleged escapement; where the sanctioning authority and the Assessing Officer proceed on differing figures, the approval can reflect non-application of mind. The text also notes that extended limitation for reopening under section 149(1) depends on the escapement ultimately relied upon crossing the prescribed monetary threshold. Here, the figures moved from Rs. 1,11,37,000 to Rs. 66,13,961 and were finally confined to Rs. 27,00,000, showing inconsistency in the basis for sanction and failure to meet the threshold for extended reopening. The reopening was therefore treated as invalid. en-us Fri, 24 Apr 2026 00:00:00 +0530 Mon, 27 Apr 2026 08:21:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790555 Reassessment approval under section 151 must be based on a clear and consistent view of the alleged escapement; where the sanctioning authority and the Assessing Officer proceed on differing figures, the approval can reflect non-application of mind. The text also notes that extended limitation for reopening under section 149(1) depends on the escapement ultimately relied upon crossing the prescribed monetary threshold. Here, the figures moved from Rs. 1,11,37,000 to Rs. 66,13,961 and were finally confined to Rs. 27,00,000, showing inconsistency in the basis for sanction and failure to meet the threshold for extended reopening. The reopening was therefore treated as invalid. Case-Laws Income Tax Fri, 24 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790555