Post-three-year reassessment needs higher-authority sanction; defective approval voided the notice and consequent assessment under tax law.

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....A reassessment notice issued after expiry of three years from the end of the relevant assessment year required sanction from the higher specified authority under section 151(ii); approval from the Principal Commissioner was insufficient. The Tribunal held that section 151 distinguishes between notices within three years and those issued later, and non-compliance with the correct sanction requirement goes to jurisdiction. The notice under section 148 was therefore invalid, and the assessment framed pursuant to it was quashed.....