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    <title>2026 (7) TMI 741 - ITAT HYDERABAD</title>
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    <description>Reassessment beyond three years from the end of the relevant assessment year requires prior sanction from the authority specified in section 151(ii), and approval from the Principal Commissioner of Income Tax does not satisfy that requirement. The text explains that where notice under section 148 was issued after that period, sanction had to come from the Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General, as applicable. It treats sanction by an incorrect authority as a jurisdictional defect going to the root of the proceedings. On that basis, the reassessment and consequential assessment under section 147 read with section 144B were stated to be invalid, rendering challenges to the additions academic.</description>
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    <pubDate>Wed, 08 Jul 2026 00:00:00 +0530</pubDate>
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      <title>2026 (7) TMI 741 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=794855</link>
      <description>Reassessment beyond three years from the end of the relevant assessment year requires prior sanction from the authority specified in section 151(ii), and approval from the Principal Commissioner of Income Tax does not satisfy that requirement. The text explains that where notice under section 148 was issued after that period, sanction had to come from the Principal Chief Commissioner, Principal Director General, Chief Commissioner, or Director General, as applicable. It treats sanction by an incorrect authority as a jurisdictional defect going to the root of the proceedings. On that basis, the reassessment and consequential assessment under section 147 read with section 144B were stated to be invalid, rendering challenges to the additions academic.</description>
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