The assessee challenged a reopening notice for the assessment year 2016-17 on the ground that it was issued after a period of three years from the end of the relevant assessment year without valid sanction. The High Court, relying on its binding precedent in Siemens Financial Services (P) Ltd v. DCIT(2023) 154 taxmmann.com 159/ 457 ITR 647 (Bom)(HC)   held that where more than three years have elapsed, sanction for issuing a notice under section 148 must be granted under section 151(ii) by the Principal Chief Commissioner or a higher-ranking authority. Since the sanction in the assessee’s case was granted by the authority specified under section 151(i), the Court held the sanction to be without jurisdiction. Accordingly, the Court quashed the impugned order under section 148A(d) and the reassessment notice issued under section 148. (AY. 2016-17)