https://www.taxtmi.com/caselaws?id=470017 Delay in filing an appeal may be condoned where non-receipt of notices and surrounding circumstances show that the delay was not deliberate, reflecting the principle that substantial justice should prevail over technical objections. The notes state that reassessment under section 148A(d) requires approval from the specified competent authority and within the applicable statutory timeframe. Approval obtained from the Principal Commissioner instead of the Principal Chief Commissioner, and sought beyond three years from the end of the assessment year, is described as a jurisdictional defect going to the root of the proceedings. The reassessment is therefore presented as invalid and a nullity, with remaining issues becoming academic. en-us Wed, 12 Mar 2025 00:00:00 +0530 Mon, 13 Jul 2026 18:58:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470017 Delay in filing an appeal may be condoned where non-receipt of notices and surrounding circumstances show that the delay was not deliberate, reflecting the principle that substantial justice should prevail over technical objections. The notes state that reassessment under section 148A(d) requires approval from the specified competent authority and within the applicable statutory timeframe. Approval obtained from the Principal Commissioner instead of the Principal Chief Commissioner, and sought beyond three years from the end of the assessment year, is described as a jurisdictional defect going to the root of the proceedings. The reassessment is therefore presented as invalid and a nullity, with remaining issues becoming academic. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470017