The reassessment notices under section 148 were issued after the expiry of the extended limitation period recognised by the Supreme Court in Union of India v. Rajeev Bansal. The Tribunal held that the notices issued for the relevant assessment years were barred by limitation and, therefore, no valid reassessment proceedings were pending before the Assessing Officer. Since the reference made to the Principal Commissioner under the second proviso to section 143(3) was founded on invalid reassessment proceedings, the orders withdrawing approval under section 10(23C)(vi) were quashed. The Tribunal held that the second proviso to section 143(3), inserted with effect from 1 April 2022, applies prospectively from assessment year 2022-23. Consequently, the Assessing Officer had no authority to invoke the proviso for the earlier assessment years under consideration while making a reference for withdrawal of approval under section 10(23C)(vi). The consequential orders were therefore held to be without authority of law.  The approval granted to the assessee under section 10(23C)(vi) was withdrawn by the Principal Commissioner pursuant to a reference made by the Assessing Officer. The Tribunal held that, under the applicable notifications, only the Commissioner (Exemption) having territorial jurisdiction was competent to grant or withdraw approval under section 10(23C)(vi). As the impugned orders were passed by an authority lacking jurisdiction, they were liable to be quashed. (AY. 2018-19 to 2020-21).