Allowing the petition the Court held that  since the notice was being issued beyond the four years period prescribed under the unamended provisions of section 151(1) of the Act, it ought to have the satisfaction accorded by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner which was not so. The notice dated March 27, 2021 issued under section 148 of the Act and consequent order overruling the assessee’s objections were quashed.(AY.2015-16)