Dismissing the petition, that there had been application of mind by the authority while granting the approval under section 151 for issue of notice under section 148 for reopening the assessment under section 147. During the assessment proceedings the assessee could raise all grounds before the Assessing Officer who should pass his orders in accordance with law. If the assessee was aggrieved by such order, he could avail of the remedy of filing appeal under the provisions of the Act. (AY.2015-16)