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    <title>2026 (5) TMI 544 - ITAT DELHI</title>
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    <description>For reopening an assessment beyond three years from the end of the relevant assessment year, sanction under section 151 had to be obtained from the Principal Chief Commissioner of Income Tax. Approval instead taken from the Principal Commissioner of Income Tax was treated as sanction by the wrong authority, creating a jurisdictional defect that went to the root of the reassessment. The reassessment for Assessment Year 2017-18 was therefore unsustainable and was quashed for want of valid approval from the competent authority.</description>
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      <description>For reopening an assessment beyond three years from the end of the relevant assessment year, sanction under section 151 had to be obtained from the Principal Chief Commissioner of Income Tax. Approval instead taken from the Principal Commissioner of Income Tax was treated as sanction by the wrong authority, creating a jurisdictional defect that went to the root of the reassessment. The reassessment for Assessment Year 2017-18 was therefore unsustainable and was quashed for want of valid approval from the competent authority.</description>
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