#Jurisdictional Authority

ITAT Delhi ruled that reassessment notices under Section 148 of the Income Tax Act must be approved by the competent authority based on the timing of issuance. For notices issued after three years, only the Pr. Chief Commissioner-not the Pr. CIT-can grant approval. The Tribunal quashed the assessment order, reinforcing strict procedural compliance in tax reassessment.

ITAT Mumbai ruled that reassessment proceedings initiated beyond three years from the relevant assessment year are invalid if approved by an incorrect authority under Section 151(ii) of the Income Tax Act. The tribunal held that only the 'specified authority' as amended in 2021 could grant approval, rendering the notice and subsequent proceedings null and void. This decision reinforces jurisdictional compliance in tax reassessment cases, impacting taxpayers and revenue authorities alike.