https://www.taxtmi.com/caselaws?id=798089 Section 151(ii) requires approval from the higher specified sanctioning authority where a reassessment notice is issued more than three years after the end of the relevant assessment year. Approval by a Principal Commissioner does not meet that requirement. The prescribed sanction is a jurisdictional safeguard, not an internal administrative formality. Deeming an earlier notice as issued under section 148A(b), or applying TOLA, does not remove the requirement for valid approval before the consequential section 148 notice. Defective approval is not substantial compliance and cannot be cured under sections 292B or 292BB; it invalidates the reassessment notice, proceedings and order. en-us Fri, 14 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798089 Section 151(ii) requires approval from the higher specified sanctioning authority where a reassessment notice is issued more than three years after the end of the relevant assessment year. Approval by a Principal Commissioner does not meet that requirement. The prescribed sanction is a jurisdictional safeguard, not an internal administrative formality. Deeming an earlier notice as issued under section 148A(b), or applying TOLA, does not remove the requirement for valid approval before the consequential section 148 notice. Defective approval is not substantial compliance and cannot be cured under sections 292B or 292BB; it invalidates the reassessment notice, proceedings and order. Case-Laws Income Tax Fri, 14 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798089