https://www.taxtmi.com/caselaws?id=466971 Prior sanction under section 151(ii) is a mandatory precondition to assume jurisdiction for issuing a notice under section 148 and for passing an order under section 148A(d) where more than three years have elapsed; TOLA extended temporal deadlines but did not alter the identity of the competent sanctioning authority and CBDT instructions did not dispense with the statutory sanction requirement. Because the notice was issued after three years with approval from an authority not specified in section 151(ii) and the Assessing Officer supplied particulars only after prescribed timelines, the notice, the 148A(d) order and consequential proceedings under section 147 were held invalid and quashed, and the appeal allowed for the assessee. en-us Wed, 30 Apr 2025 00:00:00 +0530 Sat, 28 Feb 2026 08:40:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466971 Prior sanction under section 151(ii) is a mandatory precondition to assume jurisdiction for issuing a notice under section 148 and for passing an order under section 148A(d) where more than three years have elapsed; TOLA extended temporal deadlines but did not alter the identity of the competent sanctioning authority and CBDT instructions did not dispense with the statutory sanction requirement. Because the notice was issued after three years with approval from an authority not specified in section 151(ii) and the Assessing Officer supplied particulars only after prescribed timelines, the notice, the 148A(d) order and consequential proceedings under section 147 were held invalid and quashed, and the appeal allowed for the assessee. Case-Laws Income Tax Wed, 30 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466971