https://www.taxtmi.com/highlights?id=101100 Collateral challenge to the jurisdiction of reassessment proceedings was held maintainable in an appeal against penalty where the penalty was founded on that reassessment. After three years from the end of the relevant assessment year, approval for notice under section 148 had to be obtained from the authority specified in section 151(ii); approval by the PCIT was insufficient. Because the notice under section 148 and the reassessment order were issued with the wrong sanction, the reassessment was void and the consequential penalty under section 271E could not survive. en-us Thu, 25 Jun 2026 08:27:37 +0530 Thu, 25 Jun 2026 08:27:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101100 Collateral challenge to the jurisdiction of reassessment proceedings was held maintainable in an appeal against penalty where the penalty was founded on that reassessment. After three years from the end of the relevant assessment year, approval for notice under section 148 had to be obtained from the authority specified in section 151(ii); approval by the PCIT was insufficient. Because the notice under section 148 and the reassessment order were issued with the wrong sanction, the reassessment was void and the consequential penalty under section 271E could not survive. Highlights Income Tax Thu, 25 Jun 2026 08:27:37 +0530 https://www.taxtmi.com/highlights?id=101100