Notice issued u/s 148 with approval of CIT in place of JCIT has no validity

Issue before court: Whether CIT can give approval for initiating proceeding u/s 147 in place of JCIT who is prescribed authority to give such approval u/s 151 (2) of the Income-tax Act. Brief facts: For AY2002-03, assessment was framed under Section 143(1). Based upon information received by the AO, a satisfaction note was recorded sometime in early 2009 and a notice was issued in 25.03.2009 i.e. four years beyond the end of the assessment year. Since the case was reopened after expiry of four years approval for initiating proceedings u/s 147 was taken from jurisdictional CIT. The re-assessme...