Reassessment Sanction Failure

This ruling is a textbook reaffirmation of jurisdictional discipline in reassessment law post Finance Act, 2021. 

The Tribunal underscores that the revamped reassessment regime is approval-sensitive and procedurally exacting, and any deviation, especially in sanction hierarchy, renders proceedings unsustainable. 

The decision reinforces that jurisdictional defects are incurable, even if substantive additions may otherwise appear justified.