Procedural Defect Invalidates Tax Reassessment: Sanction from Unauthorized Official Renders Entire Proceedings Legally Unsustainable Under Section 148

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....ITAT adjudicated a case involving procedural invalidity of assessment reopening. The tribunal held that sanction obtained from an incorrect Specified Authority renders the entire reassessment proceedings legally unsustainable. The court emphasized that obtaining approval from the appropriate hierarchical authority (Principal Chief Commissioner or Principal Director General) is a mandatory precondition for invoking reassessment jurisdiction under section 148. Where sanction is procured from an unauthorized official, the reopening of assessment stands quashed. The tribunal ruled in favor of the assessee, invalidating the reassessment notice due to procedural non-compliance with statutory requirements regarding sanctioning authority.....