Allowing the petition, the Court held that the original notice under section 148 of the Act (deemed to be a show-cause notice under section 148A(b) of the Act in terms of the decision in the case of UOI  v. Ashish Agarwal, (2022) 444 ITR 1 (SC) was issued on June 28, 2021, that is, two days prior to the expiry of the limitation period as extended by virtue of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Thus, the Assessing Officer had two days to issue the notice under section 148 of the Act after receiving the reply dated June 8, 2022 filed by the assessee. Since the period was less than seven days, the Assessing Officer had, by virtue of the fourth proviso to section 149(1) of the Act, seven days to pass an order under section 148A(d) of the Act (which was necessarily required to accompany a notice under section 148 of the Act). The period expired on June 16, 2022. Therefore, the order passed under section 148A(d) of the Act was beyond the period of limitation. Court also held that the notice was liable to be set aside on the ground that it was issued without the approval of the authority specified under section 151 of the Act. Since the notice was issued beyond the period of three years from the end of the relevant assessment year, in terms of section 151(ii) of the Act, it was required to be approved by the Principal Chief Commissioner or Principal Director General or, where there is no such authority, by the Chief Commissioner or Director General. The determination of the specified authority for grant of approval under section 151 of the Act depended on whether the notice under section 148 of the Act was being issued after the expiry of three years from the end of the relevant assessment year or within the said period. The order dated July 29, 2022, passed under section 148A(d) of the Act was not sustainable. Consequently, the subsequent proceedings, including the assessment order dated May 23, 2023, were not sustainable. The order passed under section 148A(d) of the Act, the notice issued under section 148 of the Act, as well as the assessment order dated May 23, 2023 and the demand raised pursuant thereto, were set aside. (AY. 2016-17)