The batch of writ petitions assails the validity of the reassessment action initiated by the respondents under section  148 of the Act  and pertaining to assessment year 2015-16 were assailed before the Court was a violation of the provisions contained in section n 151. The sanction was granted by Joint Commissioner.    Allowing the petitions,  the Court held that (i)  tested on the principles enunciated in Suman Jeet Agarwal(2022) 449 ITR 517 (Delhi)(HC)  the notices issued under section 148 for the assessment year 2015-16 had been issued and dispatched after April 1, 2021 but would be of little relevance or significance considering the fact that all the notices were approved by the Joint Commissioner, an authority recognised under the unamended section 151 of the 1961 Act.  (ii) That section 3 of the 2020 Act established that where the time limit for the completion or compliance of any action under a specified Act were to fall between March 20, 2020 to December 31, 2020, the period for completion and compliance would stand extended up to March 31, 2021 or such other dates thereafter as may be specified by the Union Government by way of a notification which was lastly up to June 30, 2021. The Finance Act, 2021 ([2021] 432 ITR (St.) 52) was enacted thereafter and came into effect from April 1, 2021. The terminal point for initiation of reassessment for the assessment year 2015-16 in ordinary circumstances would have been March 31, 2020 and that date fell within the period stated in section 3 of the 2020 Act. Therefore, the period for issuance of notice for the assessment year 2015-16, stood extended up to June 30, 2021.  (iii) That the fallacy of the submissions of the Revenue was even more evident on consideration of the fact that even if the reassessment actions were initiated as per the extended timelines in terms of the 2020 Act, and thus after the period of four years, section 151 incorporated adequate measures to deal with such a contingency and in unambiguous terms identified the authority for the purposes of sanction and approval. Section 151 distributed the powers of approval amongst a set of specified authorities based upon the lapse of time between the end of the relevant assessment year and the date when reassessment was proposed. Even if the reassessment was proposed to be initiated with the aid of the 2020 Act after the expiry of four years from the end of the relevant assessment year, the authority statutorily empowered to confer approval would be the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. It would only be in a case where the reassessment was proposed to be initiated before the expiry of four years from the end of the relevant assessment year that approval could have been accorded by the Joint Commissioner. Similar would be the position which would emerge if the actions were tested on the basis of the amended section 151 and which divided the power of sanction amongst two sets of authorities based on whether reassessment was commenced within three years or thereafter. (iv) That once it was conceded that the notice was issued four or three years after the end of the relevant assessment year, the approval granted by the Joint Commissioner would not be compliant with the scheme of section 151. The grant of approval by the Joint Commissioner for issue of notice under section 148 for the assessment year 2015-16 was unsustainable.  (v) That the contention of the Revenue that the use of the expression “sanction” in section 3 of the 2020 Act was meritless when the indisputable fact that the set of provisions which were concerned nowhere prescribed a time-frame within which sanction was liable to be accorded. “Sanction” when used in section 3 of the 2020 Act catered to those contingencies where a specified Act had prescribed a particular time limit within which an action could be approved. That was clearly not the position which obtained herein and hence the reassessment was unsustainable. The notices issued under section 148 based on a sanction obtained from the Joint Commissioner were quashed.(AY. 2015-16)