https://www.taxtmi.com/caselaws?id=791249 Reassessment under section 148 was held invalid because the sanction under section 151 was obtained from the Principal Commissioner instead of the specified higher authority required for a notice issued beyond three years from the end of the relevant assessment year. That defect was treated as jurisdictional because valid approval by the correct specified authority is a precondition to reopening. As the approval did not satisfy the mandatory statutory requirement, the notice was bad in law and the assessment made on its basis could not stand. The reassessment notice and consequential assessment were therefore quashed. en-us Wed, 15 Apr 2026 00:00:00 +0530 Fri, 08 May 2026 07:29:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791249 Reassessment under section 148 was held invalid because the sanction under section 151 was obtained from the Principal Commissioner instead of the specified higher authority required for a notice issued beyond three years from the end of the relevant assessment year. That defect was treated as jurisdictional because valid approval by the correct specified authority is a precondition to reopening. As the approval did not satisfy the mandatory statutory requirement, the notice was bad in law and the assessment made on its basis could not stand. The reassessment notice and consequential assessment were therefore quashed. Case-Laws Income Tax Wed, 15 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791249