On a writ the Court held that there was a discrepancy between the draft of the order under section 148A(d) of the Act which stated that income of Rs.97,06,911 had escaped assessment and the approval granted by the Principal Commissioner, which showed the income which had escaped assessment as Rs. 63,16,784, and that therefore, the approval under section 151 was obtained and granted without application of mind. The court  quashed the order under section 148A(d) and the consequent notice issued under section 148 for reassessment. The Supreme Court dismissed the petition on the grounds of delay  of 181 days and also  on the merits.(AY.2019-20)