Income Tax Order u/s 148 unsustainable without Sanction u/s 151: Bombay HC

The Bombay High Court has ruled that an Income Tax order under Section 148 is unsustainable if it lacks sanction under Section 151. The case involved an assessment where the Income Tax Authority issued a notice without obtaining prior approval from the competent authority. The court emphasized that such approval is mandatory to validate the notice and ensure compliance with legal procedures. Without this sanction, the notice is deemed invalid, and any subsequent proceedings based on it are considered void. This decision underscores the importance of adhering to procedural requirements in tax assessments to uphold their legality and fairness.