The petitioner, Ritaben Arvindbhai Patel, challenged a reassessment order under Section 148A(d) and notice under Section 148 of the Income Tax Act, both dated 01.04.2022, issued for Assessment Year 2018-19 on account of alleged 'on-money' income of Rs.29,42,074 from a land sale. The core dispute was whether the sanction for reassessment was granted by the competent authority under Section 151 of the Income Tax Act — specifically, whether the Principal CIT (Central), Surat, had jurisdiction to grant sanction on 01.04.2022, the day after the ordinary three-year limitation period expired on 31.03.2022, when the Principal Chief CIT was arguably required. The Gujarat High Court held that the proviso to Section 151 inserted by the Finance Act 2023 (w.e.f. 01.04.2023) operates prospectively and cannot retrospectively validate the sanction granted on 01.04.2022, as it affects vested rights and alters jurisdiction without express legislative intent for retrospectivity. Accordingly, the Court found the impugned order and notice to be without jurisdiction and quashed them.