https://www.taxtmi.com/caselaws?id=472303 Jurisdictional objections to reassessment may be raised collaterally in an appeal against revision under section 263 because revision presupposes a legally valid assessment order. A defect in the authority to initiate reassessment cannot be cured by waiver, acquiescence, participation, or failure to challenge the reassessment directly. Where more than three years have elapsed, section 151(ii) requires sanction from the Principal Chief Commissioner or Chief Commissioner; approval by the Principal Commissioner under section 151(i) does not meet that condition. Reassessment without competent sanction is void ab initio and cannot support revisionary jurisdiction under section 263. en-us Thu, 29 Jan 2026 00:00:00 +0530 Wed, 07 Oct 2026 13:42:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472303 Jurisdictional objections to reassessment may be raised collaterally in an appeal against revision under section 263 because revision presupposes a legally valid assessment order. A defect in the authority to initiate reassessment cannot be cured by waiver, acquiescence, participation, or failure to challenge the reassessment directly. Where more than three years have elapsed, section 151(ii) requires sanction from the Principal Chief Commissioner or Chief Commissioner; approval by the Principal Commissioner under section 151(i) does not meet that condition. Reassessment without competent sanction is void ab initio and cannot support revisionary jurisdiction under section 263. Case-Laws Income Tax Thu, 29 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472303