Reassessment beyond four years requires approval from the statutory authority under section 151(1); approval by an Additional Commissioner was insufficient.

A notice for reopening an assessment beyond four years from the end of the relevant assessment year requires prior satisfaction of the authorities named in section 151(1) of the Income-tax Act, 1961. Approval by an Additional Commissioner does not meet that jurisdictional precondition because the officer is not one of the authorities specified in the statute. The recorded approval was therefore invalid, and the section 148 notice was held liable to be quashed.

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Issues: Whether a notice issued under section 148 of the Income-tax Act, 1961 for reopening an assessment beyond four years from the end of the relevant assessment year was valid when the recorded approval was granted by an Additional Commissioner instead of the authority specified in section 151(1).

Analysis: The statutory scheme required satisfaction of the Principal Chief Commissioner, Chief Commissioner, Principal Commissioner or Commissioner before issuance of notice under section 148 after the expiry of four years from the relevant assessment year. The period involved was beyond four years, so compliance with section 151(1) was mandatory. An Additional Commissioner was held not to be equivalent to the authorities named in section 151(1), and the approval obtained from that officer did not satisfy the jurisdictional precondition for reopening.

Conclusion: The notice under section 148 was invalid and liable to be quashed.

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