“Chief Commissioner”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(15A) / Section 1172,876 judgments

The decision most relied on for Chief Commissioner is Pvt Ltd. v. ACIT (93 Taxmann.com 296), cited in 98 judgments on BharatTax.

Leading authorities on Chief Commissioner

Pvt Ltd. v. ACIT

93 Taxmann.com 296 · 2018 · High Court

citing judgments

Approval granted by the Principal Chief Commissioner or Principal Commissioner under Section 151 for reassessment proceedings under Section 148 must reflect due application of mind. A mere endorsement of "approved" without reasons or reference to material is insufficient, as the approval serves as a safeguard and must be meaningful, not ritualistic or formal.

Financial Services Pvt. Ltd. v. Dy. CIT

457 ITR 647 · 2023 · High Court

citing judgments

The amended Section 151 of the Income-tax Act, governing the sanction for reassessment proceedings under Sections 148 and 148A, applies to cases initiated under the new reassessment regime. The specified authority for granting such sanction becomes the Principal Chief Commissioner or Principal Director General if more than three years have elapsed from the end of the relevant assessment year.

Ghanshyam K. Khabrani v. ACIT

346 ITR 443 · 2012 · High Court

citing judgments

The reassessment proceedings are invalid if the required sanction under Section 151 of the Income Tax Act is not obtained from the statutorily designated authority or if the approval is granted mechanically without due satisfaction. Approval by a higher authority cannot substitute the satisfaction of the authority specified in Section 151.

Mohinder Singh Gill v. Chief Election Commissioner

1 SCC 405 · 1978 · Supreme Court

citing judgments

When a statutory authority issues an order based on specific grounds, its validity must be assessed solely by those stated grounds and cannot be supported or improved by additional reasons provided later in affidavits or other means. An order that is invalid at its inception cannot be validated by subsequent justifications.

Sahara India v. CIT & Others

216 CTR 303 · 2008 · Reported

citing judgments

The requirement of prior approval from the Chief Commissioner or Commissioner under Section 142(2A) is a crucial safeguard against arbitrary assessment, placing a significant responsibility on the approving authority to ensure its genuine application and prevent it from becoming a mere formality.

New Noble Educational Society v. Chief Commissioner of Income Tax

448 ITR 594 · 2022 · Supreme Court

citing judgments

An institution qualifies as an 'educational institution' for tax exemption, including under Section 10(23C)(iiiab), only if it imparts structured, formal education, distinguishing it from general public utility activities under Section 2(15).

Star India Private Limited v. Chief Commissioner of Central Excise

280 ITR 321 · 2006 · Supreme Court

citing judgments

The Supreme Court holds that while the Legislature can enact laws retrospectively, this power does not normally extend to creating an offence or penal liability retroactively, nor to withdrawing a benefit already granted under a statute through retrospective amendment.

Oxford Academy for Career Development v. Chief CIT

315 ITR 382 · 2009 · High Court

citing judgments

The Commissioner of Income Tax (CIT) has no power to cancel registration granted under Section 12A of the Income Tax Act retrospectively, especially when there is no express provision in the Act for such cancellation and the order is quasi-judicial in nature.

Judgments citing Chief Commissioner

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle- 15, Delhi

ITA 3000/DEL/2024[2012-13]Status: DisposedITAT Delhi20 May 2025AY 2012-13

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special

Section 132(4)Section 153ASection 50Section 68

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”: NEW DELHI BEFORE SHRI C. N. PRASAD, JUDICIAL MEMBER AND SHRI M. BALAGANESH

Sushen Mohan Gupta, New Delhi vs. Assistant Commissioner of Income Tax, Central Circle -15, Delhi

ITA 2999/DEL/2024[2011-12]Status: DisposedITAT Delhi20 May 2025AY 2011-12

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department

Section 132(4)Section 153ASection 50Section 68

reported in 2008 (4) TMI 4 - Supreme Court, in para 6 observed as under:- ―Similarly, the requirement of previous approval of the Chief Commissioner or the Commissioner in terms of the said provision being an inbuilt protection against any arbitrary or unjust exercise of power by the Assessing Officer, casts ... requirement of the previous approval, envisaged in the Section is not turned into an empty ritual. Needless to emphasise that before granting approval, the Chief Commissioner or the Commissioner, as the case may be, must have before him the material on ITA Nos. 2999 to 3005/Del/2024 Sushen Mohan Gupta

Vimalbhai Mohanbhai Nariya Prop. S.M. Corporation, Jamnagar vs. The Income Tax Officer, TDS-3, Jamnagar

In the result, appeal filed by the assessee is allowed, for statistical purpose/

ITA 359/RJT/2018[2013-14]Status: DisposedITAT Rajkot19 May 2025AY 2013-14

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकरअपीलसं./ Ita No. 359/Rjt/2018 िनधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing)

For Appellant: Shri V. P. Sutaria, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 206Section 206CSection 206C(1)Section 234ESection 234eSection 260CSection 44A

trading purposes (1B) The person responsible for collecting tax under this section shall deliver or cause to be delivered to the 21 Principal Chief Commissioner or Chief Commissioner or 2"Principal Commissioner or Commissioner one copy of the declaration referred to in sub-section (1A) on or before the seventh

DCIT, Circle-2(1), Hyderabad vs. Ingenerie Technologies Solutions Private Limited, Hyderabad

In the result, appeal of the Revenue is allowed for statistical purposes

ITA 837/HYD/2024[2016-17]Status: DisposedITAT Hyderabad19 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: MS Hema Murali Krishnan, AdvocateFor Respondent: Shri Narender Kumar Naik, CIT-DR

Section 147Section 148Section 68Section 69A

submitted that, if any notice issued after 01st April, 2021, the Competent Authority for sanctioning of reopening of assessment is Principal Chief Commissioner or Chief Commissioner. Further, the same 11 ITA.No.837/Hyd./2024 has not been done and the sanction was obtained from the Principal Commissioner as is evident from

Naina Manish Desai, Mumbai vs. ITO Ward 19(2)(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 262/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 May 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarnaina Manish Desai, Flat No. 6, V/S. Income Tax Officer, Ward 3Rd Floor, Triveni Building, बनाम – 19(2)(4), Piramal Walkeshwar Triveni Chs E Chambers, 5Th Floor, Block, 66 Walkeshwar Road, Lalbaug, Mumbai – Mumbai – 400 006, Maharashtra 400012, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabps9026P Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Jeet Kamdar, ARFor Respondent: Shri Kiran Unavekar, (Sr. DR)

Section 147Section 148Section 148ASection 151Section 151ASection 56(2)(vii)Section 56(2)(x)

should be after obtaining the approval of the appropriate authority under section 151 of the new regime. Therefore, the approval of the Principal Chief Commissioner of Income Tax ought to have been taken as per section 151(ii) of the Act and the approval obtained under section ... assessment year, the appropriate authority for the purpose of section 148 and section 148A of the Act is the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General of Income Tax. As against this specific requirement of section 151(ii), it is clear from the order

Income Tax Officer Ward 24(2)(1), Mumbai, Piramal Chambers, Lalbaug vs. Homewell Realty LLP, Andheri, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 1684/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 May 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Satish Mody, ARFor Respondent: Shri Hemanshu Joshi (Sr. DR)

Section 143(1)Section 144BSection 147Section 148Section 148ASection 151Section 68

Director or Commissioner or Director, if three years or less than three years have elapsed from the end of relevant assessment Year: (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than ... after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. 75. After 1 April 2021, the new regime has specified different authorities for granting sanctions under

Manisha Nitin Brahmbhatt, Mumbai vs. ITO Ward 24(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1651/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 May 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Bleι.Τ.Α. No. 1651/Mum/2025

For Appellant: Shri K. Gopal Akhilesh, A/RsFor Respondent: Shri Govindrao J. Ninawe, Sr. D/R

Section 132Section 132ASection 132oSection 133ASection 133A(5)Section 147Section 148Section 148ASection 151Section 68

Commissioner or Director, if three years or less than three years have elapsed from the end of the relevant assessment year; (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three ... have been obtained under the mandated provisions of Section 151(ii) of the Act i.e., the approval should have been obtained from the Principal Chief Commissioner whereas, the approval has been obtained from Principal Commissioner as stated in the notice u/s 148 of the Act exhibited elsewhere. आयकर अपीलीय अधिकरण

ACIT-CC-7(3), Mumbai vs. Lotus Grih Nirman Private Limited, Mumbai

In the result, appeal of the revenue is dismissed whereas cross-objection of the assessee is allowed

ITA 1484/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 May 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Acit, Cc-7(3), Mumbai M/S Lotus Grih Nirman Pvt Ltd. Room No. 655, Floor 6Th, 1201,12Th Floor Lotus Link Square, Aayakar Bhavan, M.K.Road, Vs. Near Apna Bazar, D N Nagar, New Mumbai-4000202 Link Road, Andheri West, Mumbai- 400 053 Pan No. Aabcl 0864 D Appellant Respondent Co No. 105/Mum/2025 (Arising Out Of Ita No. 1484/Mum/2025) Assessment Year: 2017-18 M/S Lotus Grih Nirman Pvt Ltd. Acit, Cc-7(3), Mumbai 1201,12Th Floor Lotus Link Room No. 655, Floor 6Th, Aayakar Square, Near Apna Bazar, D N Vs. Bhavan, M.K.Road, Nagar, New Link Road, Andheri Mumbai-4000202 West, Mumbai- 400 053 Pan No. Aabcl 0864 D Appellant Respondent

For Appellant: Mr. Niraj SoniFor Respondent: Mr. Ram Krishn Kedia, CIT-DR

Section 148Section 148ASection 151

PCIT), whereas, in terms of the statutory mandate applicable during the relevant period, such approval ought to have been obtained from the Principal Chief Commissioner of Income Tax. In support of this contention, learned counsel for the assessee has placed on record a copy of the order passed under Sections ... Principal Director or Commissioner or Director, if three years or less have elapsed from the end of the relevant assessment year; (ii) the Principal Chief Commissioner or Principal Director General or, where there is no Principal Chief Commissioner or Principal Director General, the Chief Commissioner or Director General, if more

Percival Joseph Pereira, Mumbai vs. Income Tax Officer (It) -3(3)(1), Mumbai

In the result, both the appeals by the assessee are allowed

ITA 4662/MUM/2024[2016-17]Status: DisposedITAT Mumbai19 May 2025AY 2016-17

Bench: Amit Shukla & Shri Girish Agrawal

Section 143(3)Section 271(1)(c)Section 45(5)(b)Section 56Section 56(2)(viii)

order. Contrary to this, in para 6, ld. CIT(A) noted that since the assessee had made a request for early hearing before the Chief Commissioner of Income Tax (IT), West Zone, Mumbai, the same was granted and thereafter he took up the appeal for adjudication on merit. Percival Joseph

Percival Joseph Pereira, Mumbai vs. Income Tax Officer (It)-3(3)(1), Mumbai

In the result, both the appeals by the assessee are allowed

ITA 4661/MUM/2024[2016-17]Status: DisposedITAT Mumbai19 May 2025AY 2016-17

Bench: Amit Shukla & Shri Girish Agrawal

Section 143(3)Section 271(1)(c)Section 45(5)(b)Section 56Section 56(2)(viii)

Crest Speciality Resins Private Limited, Kheda, Gujarat vs. Assistant Commissioner of Income Tax, Circle 1(1)(2), Ahmedabad (Now DCIT, Circle 1(1)(1), Ahmedabad), Gujarat

In the result, the appeal of the assessee is allowed for both the years under

ITA 1585/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad15 May 2025AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Shri B. P. Srivastava, Sr. D.R

Section 250Section 35Section 40A(2)(b)

prescribed. (4) The prescribed authority shall submit its report in relation to the approval of the said facility to the Principal Chief Commissioner or Chief Commissioner or Principal Director General or Director General in such form and within such time as may be prescribed. (5) [***] (6) No deduction shall

Crest Speciality Resins Private Limited, Kheda, Gujarat vs. Deputy Commissioner of Income Tax, Circle 1(1)(2), Ahmedabad (Now DCIT, Circle 1(1)(1), Ahmedabad), Gujarat

In the result, the appeal of the assessee is allowed for both the years under consideration

ITA 1583/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad15 May 2025AY 2015-16

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Shri B. P. Srivastava, Sr. D.R

Section 250Section 35Section 40A(2)(b)

prescribed. (4) The prescribed authority shall submit its report in relation to the approval of the said facility to the Principal Chief Commissioner or Chief Commissioner or Principal Director General or Director General in such ITA Nos. 1583&1585/Ahd/2024 Crest Speciality Resins Pvt. Ltd. vs. ACIT (Now DCIT) Asst. Years

Sandhya Goel H.No.101217, Huda, Jagadhri, Haryana vs. The Principal Commissioner of Income Tax Panchkula, Haryana

In the result, appeal of the assessee is allowed

ITA 215/CHANDI/2024[2015-2016]Status: DisposedITAT Chandigarh14 May 2025AY 2015-2016

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: ShriSudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR

Section 10(38)Section 132Section 143(3)Section 147Section 263

Assessing Officer conferred on, or assigned to, him under the orders or directions issued by the Board or by the A.Y.2015-16 11 Chief Commissioner or Director General or Commissioner authorized by the Board in this behalf under section 120; (b) “record shall include and shall be deemed always to have

Shri Balbir Singh Verma, Shimla vs. Pr.CIT, Shimla

In the result, appeal of the Assessee is allowed

ITA 314/CHANDI/2020[2015-16]Status: DisposedITAT Chandigarh14 May 2025AY 2015-16

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)

Section 133ASection 142(1)Section 143(2)Section 143(3)Section 24Section 263Section 271(1)(c)Section 36(1)(iii)

specified time limit. From the order passed, it is also not clear as to whether requisite approval was obtained from the Learned Principal Chief Commissioner of Income Tax. 3. That the Learned Principal Commissioner of Income Tax has failed to appreciate that while framing assessment, the Learned Assessing Officer

Sri Kumawat Samaj Trust, Chennai vs. CIT, Exemptions, Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 627/CHNY/2025[2020-21]Status: DisposedITAT Chennai14 May 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.627/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Sri Kumawat Samaj Trust, Vs. The Commissioner Of No. 14, 1St Floor, Kumarappa Street, Income Tax (Exemptions), Sevenwells, Chennai 600 001. Chennai. [Pan:Aavts7941K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Naresh Singh Rathore, Ca ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 29.04.2025 घोषणा की तारीख /Date Of Pronouncement : 14.05.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.12.2024 Passed By The Ld. Commissioner Of Income Tax (Exemption), Chennai For The Assessment Year 2020-21 Under Section 119(2)(B) Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Naresh Singh Rathore, CAFor Respondent: Shri AR.V. Sreenivasan, CIT

Section 111Section 115VSection 119(2)(b)Section 12ASection 132Section 132ASection 139Section 154Section 158BSection 250

under section 271 or under section 272A or an order passed by him under section 154 amending any such order; or (ii) a Principal Chief Commissioner or Chief Commissioner or a Principal Director General or Director General or a Principal Director or Director under section 263 or under section 272A

Nayanaben Vijaykumar Lakum, Bhavnagar vs. The Income Tax Officer, Ward 1(8), Bhavnagar

In the result, the appeal filed by the assessee is allowed

ITA 544/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad13 May 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Brijesh Parekh, ARFor Respondent: Shri Ravindra, Sr DR

Section 147Section 148Section 151

provisions of section 151 of the Act, the sanction of issue of notice u/s.148 of the Act has to be by the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General if more than 3 years have elapsed from the end of the relevant Assessment Year

ACIT-CC-7(3), Mumbai vs. Lotus Logistics and Developers Private Limited, Mumbai

In the result, the appeal of the Revenue is dismissed whereas cross-objection of the assessee are partly allowed

ITA 627/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 May 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Ms Kavitha Rajagopal () Assessment Year: 2017-18 Acit-Cc-7(3) Lotus Logistics & Developers Room No. 655, Floor 6Th, Private Limited Aayakar Bhavan, M.K.Road, Vs. 1301, 13Th Level, Lotus Trade Mumbai-400020 Centre, New Link Road, Near D N Nagar Metro Station, Andheri-West, Mumbai- 700013 Pan No. Aabcl 1198 G Appellant Respondent

For Appellant: Mr. Rushabh MehtaFor Respondent: DR. K. R. Subhash, Sr. DR

Section 147Section 148Section 151Section 43C

assessment beyond the three years from the end of the assessment year, sanction for issue of notice should be taken from the Principal Chief Commissioner or Chief Commissioner of the Income Tax and for period of three years or less than three years, sanction of the Principal Commissioner or Principal ... 627/MUM/2025 & CO No. 49/MUM/2025 ( emphasis supplied externally) 5. Ld. Counsel submitted that under the provision of the Law sanction of the Principal Chief Commissioner was to be taken, whereas sanction of the Principal Commissioner has been obtained for reopening and therefore, entire reopening is invalid

Juniper Networks India Private Limited, Mumbai vs. Principle Commissioner of Income Tax, Central Circle-1, Mumbai

In the result, appeal of the assessee is allowed

ITA 2042/MUM/2024[2017-18]Status: DisposedITAT Mumbai09 May 2025AY 2017-18

Bench: Sandeep Singh Karhail & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri Vijay Mehta, Ms. Forum GudhkaFor Respondent: Ms. Neena Jeph, CIT DR

Section 142(1)Section 143(3)Section 263Section 37(1)Section 92C

prejudicial to the interest of Revenue. Amendment brought in by Finance Act, 2022, w.e.f. 01.04.2022. provided jurisdiction to relevant Principal Chief Commissioner or Chief Commissioner or Principal Commissioner of 11 Juniper Network India Pvt. Ltd.; AY 2017-18 Commissioner to invoke revisionary proceedings u/s.263 to revise the order

ACIT, Central Circle-2, Jaipur vs. Unimax Buildestate Pvt Ltd, Jaipur

In the result, the appeal of the revenue as well as cross objection of the

ITA 103/JPR/2024[2014-15]Status: DisposedITAT Jaipur08 May 2025AY 2014-15

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Swapnil Parihar, JCIT-DR

Section 143(2)Section 250

Ministry of Finance Department of Revenue (CBDT) Room No. 143E, North-Block, New-Delhi Dated the 26 th of September, 2014 To AU Pr. Chief-Commissioners of Income-tax/Chief Commissioners of Income tax A All Pr. Directors-General of Income-tax/Directors-General of Income-tax Sir/Madam, Subject: - Scope

Yezdi Naushir Bharucha, Jalgaon vs. ITO Ward 1(3), Jalgaon

In the result, appeal of the assessee is partly allowed

ITA 315/PUN/2025[2017-18]Status: DisposedITAT Pune07 May 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.315/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-18 Yezdi Naushir Bharucha, V The Income Tax Officer, Bharucha House, New Laxmi S. Ward-1(3), Jalgaon. Talkies Road, Amalner – 425401. Maharashtra. Pan: Abepb6770B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Date Of Hearing 06/05/2025 Date Of Pronouncement 07/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 11.12.2024 For The A.Y.2017-18. The Assessee Has Raised The Following Grounds Of Appeal : “1] The Learned Cit(A) Erred In Holding That The Reopening U/S 148 Was Valid In Law Without Appreciating That The Notice U/S 148 Was Issued Was Invalid In Law & Accordingly, The Reassessment Order Passed U/S 147 Should Have Been Declared Null & Void.

Section 147Section 148Section 148ASection 151Section 250

more than three years have lapsed when the notice was issued for A.Y.2017-18. Hence, as per section 151 of the Act, approval of ld.Principal Chief Commissioner of Income Tax[Pr.CCIT] is required. Therefore, the notice under section 148 and order under section 148A ... Commissioner or Director, if three years or less than three years have elapsed from the end of the relevant assessment year; (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three