The High Court held that where a notice under section 148 was issued on 01.07.2022 for the assessment year 2016-17, i.e., after three years from the end of the relevant assessment year, the mandatory prior sanction had to be obtained under section 151(ii) of the Income-tax Act, 1961. In the instant case, the sanction was obtained from the PCIT, an authority specified under section 151(i). The Court ruled that an incorrect sanction rendered the notice itself invalid. Consequently, the notice and all subsequent proceedings were quashed. (AY. 2016-17)