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The assessee challenged the validity of reopening notice u/s 148 for AY 2018-19 on the ground that the mandatory sanction from the specified authority u/s 151 was not obtained. The AO had issued notice u/s 148A(b) on 23.03.2022 and notice u/s 148 on 05.04.2022, after obtaining approval only from the Principal Commissioner of Income Tax (PCIT). The assessee contended that since more than three years had elapsed from the end of the relevant assessment year (31.03.2022), the approval required under the new regime of section 151(ii) should have been obtained from the Principal Chief Commissioner / Chief Commissioner / Principal Director General / Director General, and not from the PCIT. Reliance was placed on the Supreme Court decision in UoI v. Rajeev Bansal.
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