https://www.taxtmi.com/caselaws?id=796315 Reassessment proceedings initiated after three years from the end of the relevant assessment year required approval from the authorities specifically listed in section 151(ii), not a Principal Commissioner. For AY 2018-19, approval for the section 148A(d) order and section 148 notice was granted in April 2022 by an unauthorised authority. The Finance Act 2023 proviso allowing the three-year period to account for exclusions and extensions under section 149(1) applied only from 1 April 2023 and could not retrospectively cure the defect. As section 151 sanction is a jurisdictional condition precedent, the reassessment proceedings were void from inception. en-us Thu, 23 Jul 2026 00:00:00 +0530 Tue, 04 Aug 2026 08:39:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796315 Reassessment proceedings initiated after three years from the end of the relevant assessment year required approval from the authorities specifically listed in section 151(ii), not a Principal Commissioner. For AY 2018-19, approval for the section 148A(d) order and section 148 notice was granted in April 2022 by an unauthorised authority. The Finance Act 2023 proviso allowing the three-year period to account for exclusions and extensions under section 149(1) applied only from 1 April 2023 and could not retrospectively cure the defect. As section 151 sanction is a jurisdictional condition precedent, the reassessment proceedings were void from inception. Case-Laws Income Tax Thu, 23 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796315