Reassessment invalid due to improper sanctioning authority. Principal Chief Commissioner's sanction mandatory for cases beyond 3 years.

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....Reassessment proceedings invalidated due to improper sanctioning authority. Sanction accorded by Principal Commissioner instead of Principal Chief Commissioner as mandated for cases beyond three years u/s 151(ii). Proviso to Section 151 inserting revised sanctioning authorities effective April 1, 2023, inapplicable. Impugned order and notice quashed, decided in assessee's favor, following Siemens Financial Services Private Limited case.....