Mandatory approval required from Higher Authority for issuing notice u/s 148 after expiry of 3-Year Limitation

D. Tamilselvi Vs ITO (Madras High Court) Conclusion: Reassessment proceedings initiated without obtaining prior approval from the appropriate “specified authority” under Section 151(ii) such as the Principal Chief Commissioner of Income Tax or the Principal Director General were invalid. Consequently, the impugned assessment orders and penalty notices were quashed, and the matters remitted to AO to reinitiate proceedings under Section 148 after obtaining sanction from the competent authority as mandated under the amended provisions effective from 01.04.2021. Held: In the instant case, the ...