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    <title>2026 (6) TMI 914 - ITAT MUMBAI</title>
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    <description>Reassessment initiated after three years from the end of the relevant assessment year requires approval under section 151(ii) from the specified higher authority. Where sanction for issue of notice under section 148 was obtained from the Principal Commissioner instead of the Principal Chief Commissioner, the statutory approval requirement was not met, and the notice could not sustain the reassessment. Binding jurisdictional precedent was followed to hold that approval by a lower authority is ineffective. The reassessment proceedings were quashed on this jurisdictional defect, and the merits of the addition were not examined.</description>
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      <description>Reassessment initiated after three years from the end of the relevant assessment year requires approval under section 151(ii) from the specified higher authority. Where sanction for issue of notice under section 148 was obtained from the Principal Commissioner instead of the Principal Chief Commissioner, the statutory approval requirement was not met, and the notice could not sustain the reassessment. Binding jurisdictional precedent was followed to hold that approval by a lower authority is ineffective. The reassessment proceedings were quashed on this jurisdictional defect, and the merits of the addition were not examined.</description>
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