The assessee, a non-resident Indian, filed an e-return of income for AY 2017-18 on 02.07.2017, declaring income at Rs. 80. Subsequently, it was found that out of Rs. 16,00,000/- cash seized by the police in old denomination notes (Rs 500 and 1000), Rs. 7,35,000/- belonged to the assessee. The AO reopened the case under Section 147 and issued a Section 148 notice on 29.07.2022, after obtaining prior approval from the Principal Commissioner of Income Tax (PCIT-27), Mumbai.  The assessee raised additional ground before the Tribunal on the issue of incorrect sanction by the specified Authority . The Tribunal admitted the additional ground . The assessee contended that  since more than three years had elapsed from the end of the relevant assessment year, approval should have been obtained from the Principal Chief Commissioner or Principal Director General as mandated under Section 151(ii) of the new regime and contested the validity of the notice, arguing that the approval from an unauthorized authority rendered the reassessment proceedings invalid. The ITAT held  that the issuance of notice without approval from the correct authority is a jurisdictional defect that invalidates the entire assessment.  Tribunal referred the  UOI .v.  Rajeev Bansal  (2024) 340 CTR 865 /  242 DTR  297 / 301 Taxman  238 / 167 /469 ITR 46  (SC)   UOI v . Ashsih Agarwal (2022) 286 Taxman 183/ 444 ITR 1  ( SC) he prior approval under section 148A(a) and 148(b)  wherein the prior approval under section 148A(a) and 148(b) were waived, however, the prior approval of the specified authority  according to section 151 of the new regime was not waived before passing an order u/s. 148A(d) or issuing a notices u/s. 148 of the Act on or after 01.04.2021 . Accordingly the  Tribunal quashed the Section 148 notice and the consequential reassessment order, rendering other issues academic. (ITA No. 2427/MUM/2024, dt. 10/02/2025)  (AY. 2017-18)