HC Quashes section 148 notice issued beyond 4 years as same was approved by JCIT instead of CIT

Ambika Iron and Steel Pvt. Ltd. Vs PCIT (Orissa High Court)

For the purpose of Section 151(1) of the Income Tax Act, 1961 since the reopening of the assessment was beyond 4 years, it had to have the prior approval of the Commissioner of Income Tax, and there was no such approval in the present case.

Indeed, in the notice issued under Section 148 of the IT Act on 31^st March, 2021 which has been challenged in W.P.(C) No.41826 of 2021 it has been stated that the notices had

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