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    <title>2026 (5) TMI 293 - ITAT DELHI</title>
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    <description>Reassessment proceedings were held invalid because the approval for issue of notice was obtained from the Principal Commissioner, while the governing provision required approval from the Principal Chief Commissioner after three years from the end of the relevant assessment year. That defect was treated as jurisdictional and went to the root of the reassessment power. As the mandatory precondition was not satisfied, the notice and the consequential assessment could not stand, and the assessment order was quashed in favour of the assessee.</description>
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      <description>Reassessment proceedings were held invalid because the approval for issue of notice was obtained from the Principal Commissioner, while the governing provision required approval from the Principal Chief Commissioner after three years from the end of the relevant assessment year. That defect was treated as jurisdictional and went to the root of the reassessment power. As the mandatory precondition was not satisfied, the notice and the consequential assessment could not stand, and the assessment order was quashed in favour of the assessee.</description>
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