Assessee challenged the initiation of reassessment proceedings on the ground that sanction for initiation of reassessment should be granted by the Principal Chief Commissioner. As per the section 151 approval form, that case was covered under section 149(1)(b) (beyond three years but not more than ten years). However, the Assessing Officer proceeded after obtaining administrative approval under section 151 from Commissioner, with approval granted on 27-4-2023. High Court held that since approval was granted after expiry of 3 years from end of relevant assessment year, Commissioner should have realized that it was more than three years after expiry of assessment year, which was 2019-2020 and if some time had to be excluded as per fifth proviso to section 149, that should have been mentioned in order-sheet, otherwise it would only amount to exercising jurisdiction which he never had. The order passed under section 148A(d), and the notice issued under section 148 was to be quashed. On SLP, the Court held that since there was a gross delay of 411 days in filing SLP, which had not been satisfactorily explained by revenue, the SLP filed by revenue was to be dismissed on the grounds of delay as well as merits. (AY. 2019-20)