The assessee’s reassessment proceedings for A.Y. 2017-18 were completed under section 147 read with section 143(3)/144B. Subsequently, the PCIT invoked section 263 on the ground that the Assessing Officer had failed to make proper enquiry regarding alleged penny-stock and accommodation-entry transactions. Before the Tribunal, the assessee challenged the validity of the reassessment itself on the ground of invalid sanction under section 151. The Tribunal noted that the end of A.Y. 2017-18 was 31-03-2018 and the period of three years expired on 31-03-2021. Since the order under section 148A(d) and notice under section 148 were issued on 29-07-2022, section 151(ii) was applicable, requiring sanction from the Principal Chief Commissioner or Chief Commissioner. However, sanction had been obtained from the Principal Commissioner under section 151(i). Following the Supreme Court judgment in UOI  v. Rajeev Bansal,  [2024] 301 Taxman 238 /469 ITR 46  (SC), the Tribunal held that sanction under section 151 is a jurisdictional pre-condition and sanction by an authority not prescribed by the applicable provision cannot be treated as a curable irregularity. The reassessment proceedings were therefore held to be void ab initio and non est. The Tribunal further held that a jurisdictional objection concerning the validity of reassessment could be raised in an appeal arising from an order under section 263. Since the reassessment order itself was void, there was no valid assessment order capable of being revised under section 263. Accordingly, the PCIT’s revisionary order was quashed without examining the merits of the issues sought to be revised. (AY. 2017-18 ) ( ITA No. 2555/Mum/2025 dt . 29 -1 -2026 )