https://www.taxtmi.com/caselaws?id=793883 Penalty under section 271E was held unsustainable where the reassessment proceedings themselves were invalid for want of proper approval under section 151. As the reassessment was initiated beyond three years from the end of the assessment year, approval from the competent higher authority was required, but the notice under section 148 had been issued with approval from the wrong authority. The ITAT held that this jurisdictional defect could be examined even in collateral penalty proceedings. Because the reassessment order was based on a non est notice, the penalty proceedings founded on that order could not survive, and the penalty was quashed. en-us Fri, 05 Jun 2026 00:00:00 +0530 Thu, 25 Jun 2026 08:27:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793883 Penalty under section 271E was held unsustainable where the reassessment proceedings themselves were invalid for want of proper approval under section 151. As the reassessment was initiated beyond three years from the end of the assessment year, approval from the competent higher authority was required, but the notice under section 148 had been issued with approval from the wrong authority. The ITAT held that this jurisdictional defect could be examined even in collateral penalty proceedings. Because the reassessment order was based on a non est notice, the penalty proceedings founded on that order could not survive, and the penalty was quashed. Case-Laws Income Tax Fri, 05 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793883