https://www.taxtmi.com/caselaws?id=788985 Under the substituted reassessment regime, prior approval must be obtained from the authority specified by the time elapsed from the end of the assessment year. Where more than three years have passed, approval from the higher authority under Section 151(ii) is mandatory. For Assessment Year 2016-17, the TOLA extension operated only up to 30.06.2021, but the Section 148A(d) order was passed on 30.07.2022 with approval from the Principal Commissioner. That approval was not the authority prescribed by Section 151(ii), so the Section 148A(d) order and the consequential Section 148 notice were invalid and the reassessment proceedings were quashed. en-us Mon, 23 Mar 2026 00:00:00 +0530 Wed, 01 Apr 2026 07:51:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788985 Under the substituted reassessment regime, prior approval must be obtained from the authority specified by the time elapsed from the end of the assessment year. Where more than three years have passed, approval from the higher authority under Section 151(ii) is mandatory. For Assessment Year 2016-17, the TOLA extension operated only up to 30.06.2021, but the Section 148A(d) order was passed on 30.07.2022 with approval from the Principal Commissioner. That approval was not the authority prescribed by Section 151(ii), so the Section 148A(d) order and the consequential Section 148 notice were invalid and the reassessment proceedings were quashed. Case-Laws Income Tax Mon, 23 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788985