Section 148 notice without Approval of Competent Authority is invalid

ITO Vs Kuber Fertilizers Pvt. Ltd. (ITAT Delhi) There is no dispute that the notice u/s 148 was issued to the assessee in respect of assessment years, beyond the period of four years from the end of the relevant assessment years as contemplated under the proviso to sub section (1) of Section 151 of the Act, which stipulates that after the expiry of four years from the end of the relevant assessment year, no notice u/s 148 of the Act shall be issued unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner is satisfied, on the reasons recorded by th...