Reassessment sanction requirement invalidated where approval was granted by the wrong income tax authority after three years.

Reassessment proceedings for Assessment Year 2018-19 were invalid because more than three years had elapsed from the end of the assessment year, so the sanction under Section 151(ii) had to be granted by the Principal Chief Commissioner of Income Tax. Approval by the Principal Commissioner of Income Tax did not satisfy the statutory requirement, rendering the sanction defective. The order passed under Section 148A(d) and the notice issued under Section 148 were therefore quashed and set aside.

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Issues: Whether the order passed under Section 148A(d) and the notice issued under Section 148 of the Income-tax Act, 1961 were valid when the approval was granted by the Principal Commissioner of Income Tax instead of the Principal Chief Commissioner of Income Tax for Assessment Year 2018-19.

Analysis: The Assessment Year was 2018-19 and more than three years had elapsed from the end of the assessment year. In such a case, the sanction contemplated under Section 151(ii) had to be accorded by the Principal Chief Commissioner of Income Tax. The approval by the Principal Commissioner of Income Tax was therefore not in accordance with the statutory requirement.

Conclusion: The sanction was invalid, and the order under Section 148A(d) as well as the notice under Section 148 were quashed and set aside.

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