The Tribunal examined the Section 148A(d) order and Section 148 notice and found that both had been approved by the PCIT-1, Raipur. 35, which shows that the order under section 148A (d) of the Act for AY 2016-17 dated 15.07.2022 was approved by the Principal Commissioner of Income Tax-1, Raipur (‘PCIT-1, Raipur). AR submitted that notice under section 148 dated 18.07.2022 for AY 2016-17 has been approved by PCIT-1, Raipur. 148 notice was issued on 25.07.2022, which is beyond the period of three years. Consequently, reassessment order dated 16.01.2024 also is bad in law.”.