Allowing the petition the Court held that  under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, the time to issue notice may have been extended but that would not amount to amending the provisions of section 151 of the Act. Since four years had expired from the end of the assessment year, as provided under section 151(1) of the Act, it was only the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner who could have accorded approval and not the Additional Commissioner. On this ground, the notice dated March 31, 2021 issued under section 148 of the Act, and consequent orders and notices were unsustainable.(AY.2015-16)