https://www.taxtmi.com/caselaws?id=792253 Reassessment under section 147 was held invalid because, for a notice issued within four years from the end of the assessment year, section 151(2) required approval from the Joint Commissioner. The recorded sanction was instead obtained from the Principal Commissioner, and compliance with the prescribed approving authority was treated as mandatory. The challenge based on CBDT scrutiny instructions failed because such instructions could not cure the jurisdictional defect in the reopening. The reassessment was therefore without valid jurisdiction, and the assessment order was quashed. en-us Tue, 21 Apr 2026 00:00:00 +0530 Tue, 26 May 2026 08:24:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792253 Reassessment under section 147 was held invalid because, for a notice issued within four years from the end of the assessment year, section 151(2) required approval from the Joint Commissioner. The recorded sanction was instead obtained from the Principal Commissioner, and compliance with the prescribed approving authority was treated as mandatory. The challenge based on CBDT scrutiny instructions failed because such instructions could not cure the jurisdictional defect in the reopening. The reassessment was therefore without valid jurisdiction, and the assessment order was quashed. Case-Laws Income Tax Tue, 21 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792253