The ITAT held that the notice u/s 148 of the Income Tax Act was...

The ITAT held that the notice u/s 148 of the Income Tax Act was invalid and quashed it. For the relevant assessment year 2017-18, the time limit of three years lapsed on 31.03.2021. As per the amended provisions read with TOLA, the specified authority for granting approval beyond three years is the Principal Chief Commissioner or higher officials. However, the approval was obtained from the Principal Commissioner, which was contrary to the statutory requirement. Following the Supreme Court precedents in Ashish Agarwal and Rajiv Bansal cases, the ITAT ruled that since the specified authority's sanction was not obtained as mandated, the notice u/s 148 issued beyond three years was invalid and bad in law. The decision was in favor of the assessee.