https://www.taxtmi.com/caselaws?id=800647 Reassessment notices issued after four years from the end of the relevant assessment year require prior approval from the competent authority under Section 151. When an assessee disputes the existence of that approval, the Revenue must produce the relevant approval record to establish this jurisdictional fact. A statement in the reassessment order that approval was obtained, or reliance on approval-related proceedings for another assessment year, does not prove valid sanction for the relevant year. Failure to establish prior approval invalidates the Section 148 notice and renders the consequential reassessment unsustainable. en-us Wed, 02 Sep 2026 00:00:00 +0530 Fri, 09 Oct 2026 08:30:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800647 Reassessment notices issued after four years from the end of the relevant assessment year require prior approval from the competent authority under Section 151. When an assessee disputes the existence of that approval, the Revenue must produce the relevant approval record to establish this jurisdictional fact. A statement in the reassessment order that approval was obtained, or reliance on approval-related proceedings for another assessment year, does not prove valid sanction for the relevant year. Failure to establish prior approval invalidates the Section 148 notice and renders the consequential reassessment unsustainable. Case-Laws Income Tax Wed, 02 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800647