https://www.taxtmi.com/caselaws?id=770482 The reassessment regime amended by the Finance Act, 2021 required prior approval under section 151 to be tested against the provision in force on the date sanction was granted. The Delhi HC held that the time extension under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 did not alter the statutory hierarchy of sanction. Where more than three years had elapsed from the end of the relevant assessment year, approval had to come from the authority specified in clause (ii); the notice under section 148, the order under section 148A(d), and the consequential demand were issued without the requisite approval and beyond the permissible time, and were set aside. en-us Mon, 28 Apr 2025 00:00:00 +0530 Mon, 06 Jul 2026 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770482 The reassessment regime amended by the Finance Act, 2021 required prior approval under section 151 to be tested against the provision in force on the date sanction was granted. The Delhi HC held that the time extension under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 did not alter the statutory hierarchy of sanction. Where more than three years had elapsed from the end of the relevant assessment year, approval had to come from the authority specified in clause (ii); the notice under section 148, the order under section 148A(d), and the consequential demand were issued without the requisite approval and beyond the permissible time, and were set aside. Case-Laws Income Tax Mon, 28 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770482