https://www.taxtmi.com/caselaws?id=790640 Reassessment beyond three years from the end of the assessment year required approval from the authority specified under Section 151(ii), and sanction by the Principal Commissioner was invalid for notices and orders issued in April 2022. The later proviso inserted into Section 151 from 01 April 2023 was held not to operate retrospectively, so it could not cure the jurisdictional defect. Because valid sanction was a statutory pre-condition for reopening, the reassessment initiation was without jurisdiction and the challenge succeeded. The alternate remedy objection was rejected, as writ jurisdiction remained available where the foundational reopening itself was void. en-us Fri, 24 Apr 2026 00:00:00 +0530 Tue, 28 Apr 2026 07:29:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790640 Reassessment beyond three years from the end of the assessment year required approval from the authority specified under Section 151(ii), and sanction by the Principal Commissioner was invalid for notices and orders issued in April 2022. The later proviso inserted into Section 151 from 01 April 2023 was held not to operate retrospectively, so it could not cure the jurisdictional defect. Because valid sanction was a statutory pre-condition for reopening, the reassessment initiation was without jurisdiction and the challenge succeeded. The alternate remedy objection was rejected, as writ jurisdiction remained available where the foundational reopening itself was void. Case-Laws Income Tax Fri, 24 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790640