Judgment : 1. Rule. Respondents waive service. With the consent of the parties, Rule is made returnable forthwith and heard finally. 2. The present Writ Petition challenges the impugned order dated 30th September 2025 passed by Respondent No.1 whereby the notice dated 26th July 2022 issued under Section 148 of the Income-tax Act, 1961 (for short “ the IT Act ”) has been revived pursuant to the judgment and order dated 3rd October 2024 passed by the Hon’ble Supreme Court in Union of India V/s Rajeev Bansal [Civil Appeal No. 8629, 8631 of 2024 & others, [2024] 167 taxmann.com 70 (SC) . The Petitioner has also challenged the assessment order dated 29th October 2025 passed by Respondent No.1 under Section 147 of the IT Act and consequent notice of demand dated 29th October 2025 issued under Section 156 of the IT Act and the show cause notice dated 29th October 2025 issued under Section 271(1) (c) of the IT Act. 3. Briefly stated, the relevant facts of the case are as under: (i) The Petitioner is an Association of Persons registered under Section 12A of the IT Act. For the A.Y. 2016-17, the Petitioner filed its return of income on 31st August 2016, declaring its total income of Rs.73,83,980/-. There was no scrutiny assessment order passed under Section 143(3) of the IT Act. (ii) Subsequently, Respondent No.1 issued a notice dated 7th April 2021 under the pre-existing Section 148 of the IT Act, reopening the Petitioner’s assessment for A.Y. 2016-17. On 15th April 2021, the Petitioner furnished a return of income in response to this notice. (iii) While the assessment proceedings under Section 147 of the IT Act initiated by virtue of the aforesaid notice was pending, the Hon’ble Supreme Court in Union of India V/s Ashish Agarwal [(2022) 138 taxmann.com 64 (SC)] directed that all notices under Section 148 of the IT Act issued after 31st March 2021 under the pre-existing regime be treated as notices under Section 148A(b) of the IT Act, and further directed the Revenue Officers to furnish the relevant material to the assesses and follow the procedure as per Section 148A of the IT Act. (iv) Accordingly, Respondent No.1 issued a letter dated 26th May 2022 to the Petitioner asking the Petitioner to submit its reply within two weeks. (iv) Accordingly, Respondent No.1 issued a letter dated 26th May 2022 to the Petitioner asking the Petitioner to submit its reply within two weeks. The Petitioner furnished its detailed reply on 9th June 2022, requesting Respondent No.1 to not issue any notice under Section 148. Rejecting the Petitioner’s submissions, Respondent No.1 passed an order under Section 148A(d) of the IT Act on 26th July 2022, after obtaining prior approval under Section 151(i) of the IT Act of Respondent No.2, i.e. the Principal Commissioner of Income Tax (Exemption), Mumbai. A notice dated 26th July 2022 was also issued by Respondent No.1 under Section 148 of the IT Act. (v) The Petitioner challenged the aforesaid order under Section 148A(d) of the IT Act as well as the notice under Section 148 of the IT Act in Writ Petition No. 4666 of 2022 filed before this Court. This Writ Petition was disposed of by a consolidated order dated 15th September 2023 along with several other Writ Petitions, wherein following the judgment of this Court in Siemens Financial Services Private Limited V/s Deputy Commissioner of Income Tax and Others [Writ Petition No.4888 of 2022, dated 25th August 2023] , this Court quashed the orders issued under Section 148A(d) of the IT Act as well as notices issued under Section 148 of IT Act, on the ground that sanction given under Section 151(i) of the IT Act was invalid because sanction should have been obtained under Section 151(ii) of the IT Act since the period of three years from the end of the Assessment Year 2016-17 has already expired. In this case, this Court held that the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (for short “ TOLA ”) were not applicable for the grant of sanction under Section 151 of the IT Act for A.Y. 2016-17. In this case, this Court held that the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (for short “ TOLA ”) were not applicable for the grant of sanction under Section 151 of the IT Act for A.Y. 2016-17. (vi) Being aggrieved, the Revenue filed a Special Leave Petition [Civil Appeal No. 9344 of 2024] against this Court’s aforesaid order dated 15th September 2023 before the Hon’ble Supreme Court in the Petitioner’s case, which was tagged along with Civil Appeal No. 8629 of 2024 [Union of India V/s Rajeev Bansal (supra)] and was thus disposed of by the judgment dated 3rd October 2024, wherein the aforesaid judgment of this Court was set aside to the extent of the observations made by the Hon’ble Supreme Court in Union of India V/s Rajeev Bansal (supra). (vii) Thereafter, referring to the aforesaid judgment in Union of India V/s Rajeev Bansal (supra), Respondent No.1 passed the impugned order dated 30th September 2025, rejecting the Petitioner’s objections, and revived the notice dated 26th July 2022 issued under Section 148 of the Act, and proceeded further to pass an assessment order under Section 147 of the IT Act on 29th October 2025. (viii) The Petitioner, being aggrieved by the aforesaid orders passed by Respondent No.1, has filed this Writ Petition. 4. Before us, the learned Counsel appearing for the Petitioner, submitted that Respondent No.1 has misread the judgment in Union of India V/s Rajeev Bansal (supra) inasmuch as he did not appreciate that the specified authority referred to under Section 151(i) could have granted sanction for A.Y. 2016-17 only up to 30th June 2021, even after considering the extension granted by TOLA. In the Petitioner’s case, however, the order under Section 148A(d) of the IT Act was passed on 26th July 2022, and also the notice under Section 148 of the IT Act was issued on 26th July 2022. Therefore, a sanction under Section 151(ii) of the IT Act was necessary. But in the Petitioner’s case, a sanction was obtained from the Principal Commissioner of Income Tax under Section 151(i) of the IT Act, which is not valid. In support of this contention, the learned Counsel relied upon the judgment of this Court in Ramesh Bachulal Mehta V/s. Income Tax Officer [(2025) 177 taxmann.com 606 (Bombay)] 5. We have heard the learned Counsel for the parties. 6. In support of this contention, the learned Counsel relied upon the judgment of this Court in Ramesh Bachulal Mehta V/s. Income Tax Officer [(2025) 177 taxmann.com 606 (Bombay)] 5. We have heard the learned Counsel for the parties. 6. In the present case, the period of three years from the end of the Assessment Year 2016-17 fell for completion on 31st March 2020. We, therefore, find that the present case is covered by the judgment of this Court in Ramesh Bachulal Mehta (supra), wherein it was held thus: “9. In the present case the period of three years from the end of the Assessment Year 2016-17 fell for completion on 31st March 2020. Since the expiry date fell during the time period of 20th March 2020 and 31st March 2021 contemplated under Section 3(1) of Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (for short "TOLA"), the authority specified under Section 151(i) of the new regime could have granted sanction till 30th June 2021. On perusal of the order, dated 13.07.2022, passed under Section 148A(d) of the Act, we find that the aforesaid order was passed after taking approval from Principal Commissioner of Income Tax (Respondent No.2). Since the aforesaid order was passed after the expiry of three years from the end of the Assessment Year 2016-17, as per the substituted provisions of re- assessment, the authority specified under Section 151(ii) of the Act (i.e. Principal Chief Commissioner or Chief Commissioner) was required to grant approval. Accordingly, we conclude that in the present case the approval has been obtained from the authority specified under Section 151(i) of the new regime instead of the authority specified under Section 151(ii) of the new regime. 10. The Hon'ble Supreme Court in the above case has drawn an illustration in paragraph 78 of it's order in the context of Assessment Year 2017-18, wherein it is categorically held that the authority specified under section 151(i) can accord sanction only upto 30.06.2021. This illustration makes it absolutely clear that when the period of three years from end of relevant Assessment Year expired between 20.03.2020 and 31.03.2021, the extension by virtue of TOLA was upto 30.06.2021 and not beyond. This illustration makes it absolutely clear that when the period of three years from end of relevant Assessment Year expired between 20.03.2020 and 31.03.2021, the extension by virtue of TOLA was upto 30.06.2021 and not beyond. Thus, it can be said that the period of three years from the end of the relevant Assessment Year (here AY 2016-17) expired on 30.06.2021, whereas the Respondent No.1, despite passing the order on 13.07.2022 in respect of Assessment Year 2016-17, has obtained approval of Respondent No.2 who is not the authority as prescribed under section 151(ii). 11. Non-compliance by Respondent No.1 with the provisions contained in Section 148A(d) read with Section 151(ii) vitiates the jurisdiction of the Respondent No. 1 to issue a notice under Section 148 of the Act. 12. We are clearly of the view that the present matter stands covered by the decision of Hon'ble Supreme Court in the case of UPI v. Rajeev Bansal (supra). We accordingly hold that the order dated 13.07.2022 passed under Section 148A(d) of the Act and the consequential notice issued under section 148 dated 15.07.2022 are bad in law for being violative of the provisions of Section 151(ii) of the Act. Hence they are required to be quashed and set aside.” 7. We, therefore, find that the impugned order dated 30th September 2025 passed by Respondent No.1 is, in fact, contrary to what the Hon’ble Supreme Court held in paragraph 78 of its order in Union of India V/s Rajeev Bansal (supra). We thus note that even if the order in Siemens Financial Services Private Limited (supra) stands set aside by the Hon’ble Supreme Court in Union of India V/s Rajeev Bansal (supra) on the ground of applicability of the provisions of TOLA to Section 151, yet, the sanction under Section 151(i) of the IT Act obtained by Respondent No.1 in the Petitioner’s case for the order dated 26th July 2022 passed under Section 148A(d) is still invalid as it was beyond 30th June 2021. Therefore, we are of the clear view, that on the facts of the Petitioner’s case, the judgment in Union of India V/s Rajeev Bansal (supra) is in favour of the Petitioner on the issue of sanction under Section 151. Therefore, we are of the clear view, that on the facts of the Petitioner’s case, the judgment in Union of India V/s Rajeev Bansal (supra) is in favour of the Petitioner on the issue of sanction under Section 151. Respondent No.1, therefore, lacked jurisdiction to revive the proceedings under Section 147/148 of the IT Act, which he sought to do by virtue of the impugned order dated 30th September 2025. Therefore, the impugned order dated 30th September 2025 is required to be quashed and set aside. 8. We, accordingly, quash and set aside the impugned order dated 30th September 2025 passed by Respondent No.1 whereby he revived the proceedings under section 147/148 of the IT Act, and all consequential orders/proceedings emanating therefrom, and allow this Writ Petition in terms of Prayer Clause (a), which reads thus: “(a) that this Hon’ble Court may be pleased to issue a Writ of Certiorari or a Writ in the nature of Certiorari or any other appropriate Writ, Order or direction, calling for the records of the Petitioner’s case and after going into the legality and propriety thereof, to quash and set aside the order disposing objections dated 30.09.2025 (“Exhibit – N”), assessment order u/s. 147 dated 29.10.2025 (“Exhibit – R”), notice of demand u/s. 156 dated 29.10.2025 (“Exhibit – S”) and notice u/s. 274 r. w. s. 271(1)(c) dated 29.10.2025 (“Exhibit – T”).” 9. Rule is made absolute in the aforesaid terms and the Writ Petition also stands disposed of in terms thereof. However, there shall be no order as to costs. 10. This order will be digitally signed by the Private Secretary/ Personal Assistant of this Court. All concerned will act on production by fax or email of a digitally signed copy of this order.