https://www.taxtmi.com/caselaws?id=470901 Prior sanction for an order under section 148A(d) and notice under section 148 is jurisdictional and must be obtained from the authority specified under section 151 based on the elapsed period. For assessment year 2016-17, the applicable three-year period, including the COVID-19 relaxation, expired on 30 June 2021. Approval granted on 27 July 2022 therefore required sanction from the higher specified authority under section 151(ii), not the Principal Commissioner. The proviso introduced from 1 April 2023 did not apply to the order and notice issued in July 2022. Sanction by an incompetent authority rendered the reassessment proceedings invalid. en-us Fri, 06 Feb 2026 00:00:00 +0530 Wed, 12 Aug 2026 21:28:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470901 Prior sanction for an order under section 148A(d) and notice under section 148 is jurisdictional and must be obtained from the authority specified under section 151 based on the elapsed period. For assessment year 2016-17, the applicable three-year period, including the COVID-19 relaxation, expired on 30 June 2021. Approval granted on 27 July 2022 therefore required sanction from the higher specified authority under section 151(ii), not the Principal Commissioner. The proviso introduced from 1 April 2023 did not apply to the order and notice issued in July 2022. Sanction by an incompetent authority rendered the reassessment proceedings invalid. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470901