The High Court held that where more than three years had expired from the end of the relevant assessment year (in this case, AY 2018-19), the sanctioning authority under section 151(ii) of the Income-tax Act, 1961 must be the PCCIT. Since the approval for reopening had been granted by the PCIT, the sanction was invalid. Consequently, the Court quashed the order passed under section 148A(d) and the consequent notice issued under section 148. Followed, Siemens Financial Services (P.) Ltd. v. Dy. CIT (2023) 154 taxmann.com 159/ 457 ITR 647 (Bom)(HC). (AY. 2018-19)