The Assessing Officer issued notice under sedtion 148 on 25-7-2022. On writ it was contended that  as the amount involved is more than Rs. 50 lakhs, approval has to be obtained from Principal Chief Commissioner or Chief Commissioner as defined under section 151(ii). On facts  the  amount involved in writ petition was a sum of Rs. 3.65 crores and Section 148 notice was issued on 25-7-2022, which was beyond period of three years Since approval was obtained from Principal Commissioner in terms of section 151(i) and no approval was obtained before issuance of reopening notice in terms of provision of section 151(ii), which was mandatory, reopening notice was issued in violation of provision of section 151(ii). Therefore,  reopening notice was quashed and set aside. (AY. 2016-17)