https://www.taxtmi.com/caselaws?id=795052 For reassessment action initiated after three years from the end of the relevant assessment year, Section 151(ii), before insertion of its proviso from 1 April 2023, required approval from the Principal Chief Commissioner or, in that authority's absence, the Chief Commissioner. Extensions under Section 149 did not alter the independently applicable sanctioning-authority requirement. Approval by the Principal Commissioner was therefore incompetent, and the later proviso could not apply retrospectively. Consequently, the Section 148 notice, Section 148A(d) order, and consequential reassessment proceedings were invalid and unsustainable in law. en-us Tue, 24 Mar 2026 00:00:00 +0530 Thu, 16 Jul 2026 09:07:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795052 For reassessment action initiated after three years from the end of the relevant assessment year, Section 151(ii), before insertion of its proviso from 1 April 2023, required approval from the Principal Chief Commissioner or, in that authority's absence, the Chief Commissioner. Extensions under Section 149 did not alter the independently applicable sanctioning-authority requirement. Approval by the Principal Commissioner was therefore incompetent, and the later proviso could not apply retrospectively. Consequently, the Section 148 notice, Section 148A(d) order, and consequential reassessment proceedings were invalid and unsustainable in law. Case-Laws Income Tax Tue, 24 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795052