https://www.taxtmi.com/caselaws?id=451223 ITAT Indore held that the AO's notice u/s 148 was invalid due to lack of proper approval under section 151(1). The AO had obtained approval from Joint Commissioner under section 151(2) within four years but issued the notice after four years without securing fresh approval from Principal Chief Commissioner or higher authority as mandated by section 151(1). The tribunal rejected revenue's arguments regarding TOLA protection and section 292BB applicability, ruling that obtaining lower-authority approval within four years and using it after expiry constitutes circumvention of statutory requirements, creating jurisdictional defect making entire proceedings illegal. en-us Wed, 24 Jan 2024 00:00:00 +0530 Fri, 22 Mar 2024 08:37:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451223 ITAT Indore held that the AO's notice u/s 148 was invalid due to lack of proper approval under section 151(1). The AO had obtained approval from Joint Commissioner under section 151(2) within four years but issued the notice after four years without securing fresh approval from Principal Chief Commissioner or higher authority as mandated by section 151(1). The tribunal rejected revenue's arguments regarding TOLA protection and section 292BB applicability, ruling that obtaining lower-authority approval within four years and using it after expiry constitutes circumvention of statutory requirements, creating jurisdictional defect making entire proceedings illegal. Case-Laws Income Tax Wed, 24 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451223