NARAYANA SRINIVASA vs INCOME TAX OFFICER

Whether the notice issued under section 148 of the Income Tax Act on 13.07.2022 for AY 2016-17 is time-barred as it was issued beyond the surviving period as per the Supreme Court's decision in Rajeev Bansal --- Held Yes, the notice is time-barred and void ab initio. Whether the approval obtained from the Principal Commissioner of Income Tax under section 151(ii) of the Act is valid when more than three years have elapsed from the end of the relevant assessment year --- Held No, the approval is invalid as it was obtained from an authority not vested with jurisdiction under the amended section 151.