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    <title>2026 (2) TMI 1416 - ITAT MUMBAI</title>
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    <description>A liberal approach to sufficient cause was applied, and a 79-day delay in filing the appeal was condoned because the explanation based on limited legal awareness, reliance on an accountant, and urgency over bank account attachment was found bona fide. In reassessment proceedings under the post-2021 regime, prior approval in the prescribed statutory hierarchy was treated as a jurisdictional precondition for issuing the notice and proceeding further. Because the approval was granted by an authority not competent under the applicable time-limit structure, the reassessment notice was held invalid and the consequential proceedings were quashed.</description>
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