Gujarat HC says Invalid Reassessment Sanction Cannot Be Retrospectively Cured

The Gujarat High Court held that the authority competent to sanction reassessment must be determined under the law applicable when approval is granted. The proviso inserted into Section 151 by the Finance Act, 2023, operates prospectively and cannot validate an earlier sanction. Independently, reassessment based on third-party survey material was unsustainable where no identifiable connection with the assessee or the alleged receipt of on-money was established.