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The HC held that the reassessment proceedings were without jurisdiction and must be quashed because the requisite sanction under the substituted s.151 regime was not obtained from the authority specified in s.151(ii) after the three-year period expired. TOLA extended the sanction window only to 30.06.2021; the impugned order under s.148A(d) dated 18.08.2022 and the s.148 notice dated 23.08.2022 were therefore preceded by approval from Respondent No.2 who was not the appropriate approving authority under s.151(ii). Non-compliance with s.148A(d) read with s.151(ii) vitiates jurisdiction; accordingly the HC quashed and set aside the order and notice.
The HC held that the reassessment proceedings were without jurisdiction and must be quashed because the requisite sanction under the substituted s.151 regime was not obtained from the authority specified in s.151(ii) after the three-year period expired. TOLA extended the sanction window only to 30.06.2021; the impugned order under s.148A(d) dated 18.08.2022 and the s.148 notice dated 23.08.2022 were therefore preceded by approval from Respondent No.2 who was not the appropriate approving authority under s.151(ii). Non-compliance with s.148A(d) read with s.151(ii) vitiates jurisdiction; accordingly the HC quashed and set aside the order and notice.
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