Prior Approval U/S 151 Mandatory for Notices U/S 148 Issued Beyond 3 Years, Even Under Extended TOLA Timelines

H And M Hennes And Mauritz Retail Private Limited Vs ACIT (Delhi High Court) Prior Approval U/S 151 Mandatory for Notices U/S 148 Issued Beyond 3 Years, Even Under Extended TOLA Timelines Delhi High Court held that prior approval u/s. 151 for issuance of notice under section 148 of the Income Tax Act beyond period of three years mandatory even in case of extended limitation under TOLA. Accordingly, notice and order thereon set aside. Facts- The petitioner has filed the present petition, inter alia, impugning a notice dated 30.07.2022 issued under Section 148 of the Income Tax Act, 1961 for the...