https://www.taxtmi.com/caselaws?id=469664 A 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). Approval from the Principal Commissioner was not sufficient because it was not the competent authority under the statute. The absence of valid sanction went to the root of jurisdiction, so the reopening was invalid. As the notice itself was void, the reassessment order passed under sections 147 and 144 could not be sustained and was quashed. en-us Fri, 19 Dec 2025 00:00:00 +0530 Fri, 26 Jun 2026 22:22:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469664 A 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). Approval from the Principal Commissioner was not sufficient because it was not the competent authority under the statute. The absence of valid sanction went to the root of jurisdiction, so the reopening was invalid. As the notice itself was void, the reassessment order passed under sections 147 and 144 could not be sustained and was quashed. Case-Laws Income Tax Fri, 19 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469664