Section 148A

What a section 148A notice is

Show Cause before Reassessment. The officer thinks income escaped assessment and is asking you to explain before reopening. It is a critical-severity notice in the reassessment family under the Income Tax Act 1961.

If you ignore it: Reassessment is very likely to be initiated u/s 148.

Time to reply: commonly stated as 7 days from the date of the notice — but the date printed on your own notice governs, and it overrides any general figure. THE MOST TIME-CRITICAL NOTICE IN THE SYSTEM. Treat the date printed on the notice as authoritative and alert aggressively. A strong reply here can stop reopening entirely — this is the highest-value intervention point in the whole product.

Under the Income Tax Act 2025: section 281. But read that as reference, not as the provision to cite. Under s.536(2) of the 2025 Act, a proceeding for any tax year beginning before 1 April 2026 stays under the Income Tax Act 1961 from the notice through to the appeal — so a notice arriving today for an earlier year is a 1961 Act matter, whatever today's date is.

Section 148A — the law in short

What the courts have decided on section 148A, in one screen. Read this first; open an entry when you need the facts, the reasoning and the source.

• ITO v Tej Partap Singh Supreme CourtCuts both ways
  The High Court quashed my s.148 notice because the ward officer issued it instead of the faceless unit. Does that judgment still stand?
  No, not as it stands. On 10 April 2026 the Supreme Court set aside the High Court judgments that had quashed notices issued by the jurisdictional Assessing Officer, because s.147A, inserted by the Finance Act 2026 with effect from 1 April 2021, now defines the Assessing Officer for ss.148 and 148A as an officer other than the National Faceless Assessment Centre and the assessment units in s.144B(3). The Court remitted the matters, left the validity, scope, effect, retrospectivity and applicability of s.147A open for the High Courts, and stayed further assessment and reassessment proceedings in the meantime.
• Union of India v Rajeev Bansal Supreme CourtCuts both ways
  Your notice was issued in the 1 April to 30 June 2021 window. Was it saved by TOLA, or is it dead?
  Saved, but only within limits. TOLA extends the time limit for issuing the reassessment notice and for the sanction under s.151. It does not extend anything else, and every other defence survives — including the surviving-period computation for your own assessment year.
• Red Chilli International Sales v ITO Supreme CourtCuts both ways
  The High Court threw out my writ petition against a section 148 notice saying I had an alternative remedy. Was it right to refuse to hear me at all?
  Not on that reasoning. The Supreme Court set aside the Punjab and Haryana High Court's observation that a writ petition against a reassessment notice is not maintainable because of the alternative remedy. It said the observation did not take into account several judgments of the Supreme Court on the High Court's jurisdiction, writ petitions having been entertained to examine whether the jurisdictional pre-conditions for a section 148 notice are satisfied, and that the reopening provisions as amended by the Finance Act 2021 need deeper consideration in the light of the earlier case law. The special leave petition was disposed of without any finding on the merits.
• Anshul Jain v PCIT Supreme CourtHelps department
  The order under section 148A(d) rejects everything I said and the section 148 notice has followed. Can I take it straight to the High Court?
  Usually not. The Supreme Court dismissed the assessee's petition against a High Court order refusing to interfere at that stage, saying that the notices had been issued after his objections were considered and that any grievance on the merits had to be taken to the Assessing Officer in the reassessment proceedings. It is an order dismissing a special leave petition with brief reasons, on a record that lists no counsel for the Revenue, and the same Court took a different line four months later in Red Chilli International Sales, where it set aside a refusal to entertain a writ that rested only on the existence of an alternative remedy. Read it as the ordinary rule and not as a bar, and read it today alongside section 147A, because what happens inside a reassessment is the most disturbed part of the Act.
• Union of India v Ashish Agarwal Supreme CourtHelps department
  What happened to the thousands of s.148 notices issued under the old rules after the law changed in 2021?
  Reported as treating those notices as s.148A(b) show-cause notices instead of quashing them, with directions on how they were to proceed.
• Sanjay Kumar Bijay Kumar v PCIT High CourtHelps taxpayerNo later treatment found
  The same cash deposits were already reassessed and accepted at nil. Can they reopen them again?
  No. The Orissa High Court held that where an earlier s.147 proceeding examined these very deposits, found them disclosed and assessed at NIL, and that order went unchallenged, a second reassessment on identical material is a change of opinion and an impermissible review.
• Rajeshkumar Uggamrajji Mehta v ITO High CourtHelps taxpayerNo later treatment found
  The s.148A order says I failed to answer a s.133(6) notice I never received, and ignores the documents I did file. Is that enough to get it set aside?
  Yes, on these facts. The Court held that the order under s.148A and the notice under s.148 were passed without application of mind, quashed and set aside both, and remanded the matter. The officer had simply repeated the allegation of non-response while ignoring the purchase invoices, bank statements and ledger confirmations filed with the reply.
• Deloitte Consulting India Pvt Ltd v Assessment Unit, NFAC High CourtHelps taxpayerNo later treatment found
  Your APA year has been reopened and the officer has himself re-examined whether you complied with the APA. Can he do that without a compliance audit by the Transfer Pricing Officer?
  No. Rule 10P places the compliance audit of an APA with the Transfer Pricing Officer having jurisdiction over the assessee, for each year covered by the agreement. The assessment unit had no jurisdiction to examine APA compliance on its own or to make a reassessment on that footing, and the addition of Rs 106,47,00,730 it made on that basis was beyond jurisdiction. The reopening failed independently on the s.151 sanction and because the notice was issued by the jurisdictional officer rather than the faceless assessing officer.
• Mukundbhai Manubhai Patel v ACIT High CourtHelps taxpayerNo later treatment found
  I bought mutual fund units, took the dividend the same day and booked a short-term loss. The department calls it fictitious and has reopened. Can it?
  Not on that material alone. The Gujarat High Court quashed a s.148A(d) order and s.148 notice where the reopening rested on an allegation that the fund house had manipulated its distributable surplus: purchasing units and earning dividend on the same day is not impermissible, and allegations against the fund manager cannot be extended to the investor without something showing he knowingly participated.
• Ankit Agarwal v PCCIT High CourtHelps taxpayer
  My 148A notice says I never filed a return, but I did. Is that enough to get it quashed?
  Yes, on these facts. The Patna High Court held that where the Insight Portal flag is contradicted by the Department's own records, the 'information which suggests' escapement is missing and the s.148A(b) notice, the s.148A(d) order, the s.148 notice and the demand all fall.
• Sonansh Creations P Ltd v ACIT High CourtHelps taxpayerNo later treatment found
  The officer says I took accommodation entries and I say I received nothing. Must he have material that the entries exist before he reopens?
  He must. The Delhi High Court set aside a s.148A(d) order and the consequent notice where the information was that eleven entities controlled by an entry operator had given the company fictitious loans, the company denied receiving anything from them and disclosed the bank accounts it operated, and the officer never referred to any material showing that the money had in fact come into those accounts. The Court rejected the contention that at the s.148A(d) stage the officer need form no opinion on the genuineness or veracity of the information; he must be reasonably certain that the alleged entries exist, though he need not conclusively decide that they are accommodation entries. Liberty was reserved to issue a fresh notice if material is found.
• T.K.S. Builders P Ltd v ITO High CourtHelps department
  Can the jurisdictional AO issue my s.148 notice, or must reassessment go through the faceless route?
  On this line of authority he can. The Delhi High Court held that the JAO and the faceless assessing officer have concurrent jurisdiction, that the Scheme notified under s.151A does not extinguish the JAO's power to issue notices under ss.148 and 148A, and that s.144B is procedural and is not itself a source of the power to assess or reassess.
• Jatinder Singh Bhangu v Union of India High CourtHelps taxpayerHigh Courts differ
  My reassessment notice under section 148 came from my own jurisdictional assessing officer, not through the faceless system. Is that notice good?
  No. The Punjab and Haryana High Court quashed section 148 notices issued by the Jurisdictional Assessing Officer, holding they contravene section 151A read with section 144B and the e-Assessment of Income Escaping Assessment Scheme, 2022 notified on 29 March 2022. Clause 3(b) of the scheme requires issuance of a section 148 notice through automated allocation and in a faceless manner. The Department's reliance on a CBDT office memorandum of 20 February 2023 and a Systems Directorate letter of 19 January 2024 failed: instructions and circulars can supplement but cannot supplant statutory provisions. Liberty was given to proceed in accordance with law.
• Rahul Sachan v Income Tax Officer High CourtHelps department
  The officer passed the order under section 148A(d) without answering a single point in my reply. Can I get the reassessment quashed on that ground alone?
  No, not on that ground alone. The Allahabad High Court held that section 148A does not oblige the Assessing Officer to deal with objections pointwise or to record detailed reasons. The old requirement of recording a 'reason to believe' has been done away with and replaced by a lighter, more subjective decision that it is a 'fit case' to issue a notice under section 148, on information that suggests escapement. The officer must not act whimsically, on extraneous material, or in ignorance of the reply, but an overall consideration is enough. Reading in a duty to give reasons for rejecting each objection would reintroduce 'reason to believe' by the back door. The petition was dismissed, with all merit defences left open.
• Hexaware Technologies Ltd v ACIT High CourtHelps taxpayerPartly overruled — read this first
  Your s.148 notice came from your own local officer, not from the faceless unit. Does that matter?
  In Bombay, yes. After the CBDT scheme notified under s.151A on 29 March 2022, only a Faceless Assessing Officer acting through automated allocation can issue a reassessment notice. There is no concurrent jurisdiction, and a notice from the jurisdictional officer was quashed.
• Champa Impex P Ltd v Union of India High CourtHelps departmentNo later treatment found
  The AO made no enquiry before issuing my 148A(b) notice. Does that kill the reopening?
  No, on the Calcutta view. The Division Bench read the words 'if required' in s.148A(a) as giving the Assessing Officer a discretion, so the absence of a prior enquiry does not by itself vitiate the notice.
• Sevensea Vincom P Ltd v PCIT High CourtHelps taxpayerNo later treatment found
  They reopened AY 2016-17 in 2022 for under Rs 50 lakh. Is the notice time-barred?
  Yes. The Jharkhand High Court held the three-year period for AY 2016-17 ended on 31 March 2020, and because the Department itself alleged escapement of only Rs. 39,21,450 the extended ten-year window in s.149(1)(b) was unavailable. The whole proceeding was without jurisdiction.
• Meet Lalwani v ITO High CourtHelps taxpayer
  I filed the death certificate and they still issued the 148 notice in my mother's name. Is it valid?
  No. The Madhya Pradesh High Court quashed the s.148 notice and the s.148A(d) order. Once the Department knew of the death, issuing the notice in the deceased's name was a failure to acquire jurisdiction, and ss.292B, 292BB and 159 do not cure it.
• Thorapadi Urban Co-op Credit Society Ltd v ITO High CourtHelps taxpayerHigh Courts differ
  I have received a s.148A(b) notice and a s.148A(d) order saying my society's s.80P(2)(d) deduction on interest from a co-operative bank has escaped assessment. Can I challenge the notice itself rather than fight through the reassessment?
  In this case yes. The Madras High Court, in writ petitions against s.148A(b) notices, s.148A(d) orders and s.148 notices, held that a co-operative society registered under the State Co-operative Societies Act remains a co-operative society within s.2(19) whether or not it carries on banking, so interest from a co-operative bank qualifies under s.80P(2)(d); because the impugned orders were passed without considering that, they were set aside and the notices quashed.
• Kankanala Ravindra Reddy v ITO High CourtHelps taxpayerHigh Courts differ
  My section 148A(d) order and section 148 notice came from the local assessing officer after the 2022 faceless schemes started. Can I have them quashed on that ground alone?
  Yes. The Telangana High Court quashed the section 148A(d) orders and the consequential section 148 notices in a batch of over fifty writ petitions because they were issued by the local jurisdictional officer and not in the faceless manner required by section 151A read with section 144B and the two CBDT schemes of 28 and 29 March 2022. Where a statute requires a thing to be done in a particular manner, it must be done in that manner or not at all. The Department had also ignored the Supreme Court's direction in Ashish Agarwal to proceed under the substituted provisions. The consequential orders fell with the notices.
• Chotanagpur Diocesan Trust v Union of India High CourtHelps taxpayerNo later treatment found
  My 148A(b) notice describes an enquiry but nothing was attached. Can I insist on the material?
  Yes. The Jharkhand High Court held the Department is duty-bound and mandatorily required to supply all material information, the enquiry conducted and the supporting documents along with the s.148A(b) notice; a three-page narration with no enclosures does not discharge that obligation.
• Shailendra Kumar Agarwal v Income Tax Officer, Ward 1, Rourkela High CourtCuts both waysNo later treatment found
  Can I go to the writ court against a s.148A(b) notice that simply asserts my s.80GGC claim is bogus, when the deduction was already examined in the completed assessment?
  The Orissa High Court entertained exactly that writ petition and stayed the notice. It required the Revenue to be heard on how a claim for deduction that had been made and assessed, being a donation to a registered unrecognised political party, could be said to have escaped assessment, and the petitioner argued change of opinion on the authority of CIT v Kelvinator of India Ltd. This is an interlocutory order: it decides nothing and contains no holding.
• Krishna Diagnostic Pvt Ltd v ITO High CourtHelps taxpayerNo later treatment found
  The s.148A(d) order ignores the reply I gave to a s.133(6) notice two years ago. If I take it to the High Court, does the reassessment end - or does it start again?
  It starts again, from the show-cause stage. The Court set aside the order dated 28 July 2022 under s.148A(d) and the consequential notice under s.148 of the same date, where the assessee had already told the officer, in answer to a s.133(6) notice, that the property had been purchased and not sold, and the reopening proceeded on the footing that it had been sold. Facts of that kind, already on the file, could not be given short shrift. The s.148A(b) notice of 19 May 2022 was not set aside - the Court recorded that no specific prayer had been made against it - and the officer was directed to go back to the stage prior to it.
• Charu Chains & Jewels (P) Ltd v ACIT High CourtCuts both waysNo later treatment found
  The s.148A(b) notice refers to information the officer never showed you. Can you insist on seeing it?
  Yes. The underlying information or material that triggered the proceeding must be furnished to you. The s.148A(d) order and the consequential s.148 notice were set aside — but the matter was remitted, not annulled.
• Dr Mathew Cherian v ACIT High CourtHelps taxpayer
  I'm a consultant doctor at a hospital. Can the AO reopen and tax my fees as salary?
  Not on this material. The Madras High Court set aside the s.148A(d) order and s.148 notice: the contracts showed professional autonomy, a variable fee tied to patient volume, no statutory employment benefits and freedom to practise privately, so there was no information suggesting escapement of income.
• Susai Amalanathan Antoni Vincent v Income Tax Officer High CourtHelps department
  The section 148A order does not say the information came from the Risk Management Strategy or an audit objection. Does that make the reassessment bad for want of jurisdiction?
  No. The Madras High Court held that the Risk Management Strategy is merely a phrase for an evolving departmental strategy covering all the sources from which information may be collated, and no limitation should be placed on it. The Board's circulars of 10 and 13 December 2021 list many permissible sources, and the Court held there can be no fetters on an Assessing Officer's power to gather information on which reassessment may be initiated. Here the officer had referred to information from the Director of Income Tax (Investigation and Criminal Intelligence), which sufficed for section 148A. The Rs 50 lakh condition in section 149(1)(b) was satisfied on the sale of 19 plots for Rs 1,50,25,585, and sanction under section 151 had been obtained. The petition was dismissed.
• Parmesh Chand Yadav v ITO High CourtHelps departmentSuperseded by amendment
  The AO has issued a s.148A notice on crypto exchange data showing Rs 4.65 crore of transactions. I have given my bank statements and my return — is that enough to stop the s.148 notice?
  No, not on these facts. The Court held that bank statements alone do not verify what the crypto transactions were, that the assessee ought to have produced the crypto currency ledger, and that the officer's brief consideration of the reply satisfied s.148A. The writ against the s.148 notice failed, with liberty to produce the ledger in the reassessment itself.
• Divya Capital One Private Limited v ACIT High CourtHelps taxpayer
  The section 148A(b) notice just lists my own turnover from Form 10DB, GST and TDS data and calls it escaped income, and the officer passed the 148A(d) order without my detailed reply. Can I get it set aside?
  Yes. The Delhi High Court quashed the section 148A(d) order and the section 148 notice and remanded the matter for a fresh reasoned order within eight weeks. Classifying a fact already on record as 'information' may let the officer issue a notice under section 148A(b), but it does not let him issue a reassessment notice under section 148. The notice and order were cryptic, the underlying material was never shared, no reasonable time was given, and the detailed reply on record was not considered, which breaches the mandate of section 148A(c). The Court directed that its order be sent to the CBDT.
• Mon Mohan Kohli v ACIT High CourtHelps taxpayerPartly overruled — read this first
  I got a section 148 notice after 1 April 2021 under the old reassessment provisions. Could the department still use them because of the COVID relaxation notifications?
  No, on this decision. The Delhi High Court held that the substitution of sections 147 to 151 by the Finance Act 2021 repealed the old provisions and replaced them, and that the Explanations in the notifications of 31 March 2021 and 27 April 2021, purporting to keep the old procedure alive until 30 June 2021, could not do so. Section 3(1) of the relaxation Act allows the Central Government to extend time limits and no more; a delegated legislation cannot vary the date on which Parliament's provisions take effect. Section 6 of the General Clauses Act does not save the old notices, because the new Act manifests an intention to destroy the old procedure.
• Diach Chemicals and Pigments P Ltd v DCIT ITATHelps taxpayerNo later treatment found
  The department says my purchases are bogus. Do the suppliers' returns and the input credit allowed on those invoices count for anything in the income-tax assessment?
  They are part of the record, but they are not what carried this case. The addition was deleted on a much wider evidentiary base: notices the Assessing Officer himself issued under s.133(6) came back with direct confirmations from every supplier, the primary documents were complete, the books had been audited four ways with no defect pointed out, and actual production marginally exceeded the standard yield, so the raw material bought had demonstrably gone into the goods sold. The suppliers' returns and the input credit allowed on the purchases sit in that list of supporting facts; the operative paragraph rests on the addition being estimation and surmise with no substantive basis, and does not mention them.
• Abhishek Rajeshbhai Karia v ITO, Ahmedabad ITATCuts both waysNo later treatment found
  My s.148 reassessment started over a political donation but the Assessing Officer has disallowed my 80D and 80DDB for my parents' medical expenses as well. Are those safe?
  On this order the s.80D claim of Rs 75,000 for health insurance premium and medical expenditure incurred for the assessee's parents was allowed outright, the Tribunal holding the disallowance unjustified because the expenditure was incurred for his parents and is deductible under s.80D. The s.80DDB claim of Rs 87,000 for a father diagnosed with cancer was NOT allowed: it went back to the Assessing Officer because eleven documents called for had never been produced either before him or before the CIT(A).
• Muhammed Arif Shaikh v Asst. Unit, Income Tax Department ITATHelps taxpayerNo later treatment found
  For one year the department accepted 8 per cent presumptive profit on my client's crypto sales; for the next year, on the same information, it has added the whole purchase figure under section 69C. Can it do that?
  Not on this decision. The Ahmedabad Bench held that where the same assessment unit had, for AY 2017-18, accepted a presumptive deemed profit at 8 per cent of the crypto sales, it could not for AY 2018-19 — reopened on the same common information and where the assessee had again offered 8 per cent of his crypto turnover, which the Assessing Officer accepted — go on to add the crypto purchases of Rs 17,52,838 as unexplained expenditure under s.69C. Taking inconsistent stands in the assessee's own case in two different assessment years was held not proper and against the provisions of law, and the addition was deleted.
• Nashit Suhail Ansari v ITO ITATHelps taxpayerNo later treatment found
  My client has a section 148 notice for AY 2018-19 saying he sold bitcoin and did not file a return. He was a student and made a profit of Rs 48,000. Is there anything in the notice itself?
  There may well be. The Mumbai Bench held that where AY 2018-19 was reopened by a notice dated 19 April 2022, that is beyond three years from the end of the assessment year, so the sanction under s.151 had to come from the Principal Chief Commissioner or Chief Commissioner; approval taken from the Principal Commissioner was invalid, the notice under s.148 was invalid, and everything that followed including the assessment order was void ab initio. On the merits it also held that the addition of Rs 11,28,013 could not stand where the assessee had produced bank statements showing a purchase at Rs 4,10,000 and a sale at Rs 4,58,594 and the Assessing Officer had made the addition on information alone without bringing any adverse material on record or making any enquiry.
• Balakumar Anusia v ACIT, International Taxation Circle, Madurai ITATHelps department
  My client answered neither the section 143(2) notice nor the section 142(1) notice, and the Assessing Officer has levied Rs 20,000 — Rs 10,000 for each. Is there any answer to that on appeal?
  On these facts, no. Where the assessee simply did not respond to either notice, the Chennai Bench held that the Assessing Officer had rightly levied Rs 10,000 for each default under section 272A(1)(d) and dismissed the appeal — the section's own charging words are 'a sum of ten thousand rupees for each such default or failure'.
• Statutory position — the Finance Act, 2026 and reassessment: s.147A, s.292BC, the thirty-day floor in s.148(1), and ss.153(10) and 153B(1A) CBDT Circulars & InstructionsCuts both waysUnder appeal
  The Finance Act 2026 seems to have changed the reassessment rules backwards in time. What exactly did it change, from which dates, and which of my grounds has it taken away?
  The Finance Act, 2026 (No. 4 of 2026), assented to on 30 March 2026, amended the Income-tax Act, 1961 through clauses 4 to 33, and six of those clauses are about assessment and reassessment. Clause 9 inserted section 147A, deemed in force from 1 April 2021, which makes the Assessing Officer for sections 148 and 148A an officer other than the National Faceless Assessment Centre or a section 144B(3) assessment unit, notwithstanding any judgment, section 151A or any scheme under it; clause 33 inserted section 292BC, also deemed in force from 1 April 2021, which makes an approval in any assessment or reassessment administrative and supervisory in nature and immune to attack for insufficient reasons or a missing digital signature. Clause 10 gave the section 148 notice a thirty-day floor from 30 March 2026, clause 11 substituted section 150 from 1 February 2026, and clauses 12 and 13 inserted section 153(10) and section 153B(1A), reaching back to 2009, to fix when a draft order under section 144C(1) may be made. Sections 147, 148A, 149, 151 and 151A were not amended at all. Section 147A has since been struck down by the Punjab and Haryana High Court in Jyoti Sareen v. Union of India on 10 September 2026, and that judgment was stayed by the Supreme Court on 18 September 2026, which hears the appeal on 3 December 2026.
• e-Verification Instruction 2(i) of 2024 CBDT Circulars & InstructionsCuts both waysJudgment not reachable
  A compliance campaign message arrived and nothing was done about it. What does the department do next, and does an updated return filed late in the day count for anything?
  It becomes a reopening, and yes, the updated return is credited against the figure. The Directorate of Income Tax (Systems) tells officers that what the e-Verification machinery hands them is "Information" within the statutory list, that they are to invoke s.147 and issue the s.148 notice in those cases, and that the case will sit in one of two buckets - no updated return filed, or an updated return filed during the verification without fully reconciling the mismatch. In the second bucket the amount treated as escaping is reduced by the additional income the assessee has actually shown. Two things must be said on the face of this. The instrument is an internal communication of the Directorate of Income Tax (Systems) which does not appear to have been published as departmental material and could not be traced in a subscription research database; the copy relied on here comes from an unofficial host. And nothing in it dispenses with the s.148A stage.
• CBDT Instruction No. 1/2022 — the document the whole Ashish Agarwal exercise was run on CBDT Circulars & InstructionsHelps departmentPartly overruled — read this first
  My reassessment for an old year was restarted in 2022 on the strength of a Board instruction rather than a fresh notice. What does that instruction actually say, and how much of it is the Supreme Court's?
  This is the instruction, issued under s.119 a week after Union of India v Ashish Agarwal, that told every Assessing Officer how to work out that judgment on the roughly ninety thousand notices issued under the old reassessment law between 1 April 2021 and 30 June 2021. It directs that the judgment applies to all those notices whether or not they were challenged; that the notices travel back to their original dates and new s.149 is then applied at that point, so a fresh s.148 notice may issue for assessment years 2013-14 to 2015-16 only under s.149(1)(b) and for 2016-17 and 2017-18 under s.149(1)(a); that information and material need not be given at all where escaped income for 2013-14 to 2015-16 is less than fifty lakh rupees; and that in the remaining cases the material was to be supplied by 2 June 2022, the assessee had two weeks to reply, and an order under s.148A(d) was to follow with the approval of the specified authority under s.151. Three of those directions go further than the judgment does, and the courts have said so.
• Siemens Financial Services Pvt Ltd v DCIT High CourtHelps taxpayerOverruled
  Beyond three years, who has to approve the reopening — and what if the wrong officer signed?
  Beyond three years the sanction must come from the authority in s.151(ii). Approval by the Principal Commissioner under s.151(i) is no approval at all, and the s.148A(d) order and s.148 notice built on it were quashed.

Listed strongest first: Supreme Court, then High Court, then Tribunal, then CBDT. Nothing here has yet been read in full by a chartered accountant — open an entry to see where it came from.