https://www.taxtmi.com/caselaws?id=469647 A reassessment notice issued under section 148 after more than three years from the end of the relevant assessment year required prior sanction from the authority specified in section 151(ii), namely the Principal Chief Commissioner or Principal Director General, or failing that, the Chief Commissioner or Director General. Because approval was taken from the Principal Commissioner instead, the jurisdictional safeguard was not met. The defect was treated as one going to the root of the reopening power, so the notice and the consequential reassessment order were invalid. en-us Wed, 10 Dec 2025 00:00:00 +0530 Thu, 25 Jun 2026 18:57:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469647 A reassessment notice issued under section 148 after more than three years from the end of the relevant assessment year required prior sanction from the authority specified in section 151(ii), namely the Principal Chief Commissioner or Principal Director General, or failing that, the Chief Commissioner or Director General. Because approval was taken from the Principal Commissioner instead, the jurisdictional safeguard was not met. The defect was treated as one going to the root of the reopening power, so the notice and the consequential reassessment order were invalid. Case-Laws Income Tax Wed, 10 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469647