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HC held that the reassessment order dated 13.07.2022 under s.148A(d) and the consequential notice under s.148 are void for want of valid prior sanction under s.151(ii); the AO assumed jurisdiction after the three-year period expired but obtained approval from an authority specified under s.151(i) instead of the higher authority mandated by s.151(ii), thereby vitiating jurisdiction. Applying the substituted provisions and the statutory timeline (including TOLA relief), the Court quashed and set aside the impugned order and notice and allowed the assessee's appeal.
HC held that the reassessment order dated 13.07.2022 under s.148A(d) and the consequential notice under s.148 are void for want of valid prior sanction under s.151(ii); the AO assumed jurisdiction after the three-year period expired but obtained approval from an authority specified under s.151(i) instead of the higher authority mandated by s.151(ii), thereby vitiating jurisdiction. Applying the substituted provisions and the statutory timeline (including TOLA relief), the Court quashed and set aside the impugned order and notice and allowed the assessee's appeal.
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