Assessee had entered into transactions with Fives France under Assistance Service Agreement (ASA) and filed AAR application seeking ruling on whether payments received by Fives France would be subject to withholding tax under section 195 which was declined. Meanwhile, assessee had filed its return of income which was accepted by Assessing Officer. Subsequently, a notice under section 148 was issued on basis of payment to Fives Solios SA and about three transactions with Fives France on ground that assessee had failed to deduct withholding tax. It was noted that on receipt of reasons for reopening, assessee submitted that application before AAR was only in respect of services provided under ASA between assessee and Fives France, which was operated until 31-12-2024 and transactions between assessee and Fives Solios SA and three transactions with Fives France were not covered within scope of AAR application. On writ the Court held that  since reasons for reopening were based on grossly erroneous factual foundation and assessee having actually withheld and remitted taxes in respect of transactions with Fives France that formed subject of application before AAR, impugned order under section 148A(d) and notice under section 148 were liable to be quashed. As regards issue of notice under section 148, which was issued after lapse of more than three years from end of relevant assessment year after obtaining approval from Chief Commissioner, since Chief Commissioner was not a specified authority under clause (ii) of section 151, reassessment proceedings were liable to be quashed.  (AY. 2014-15 to 2016-17).