The assessee challenged a notice dated 31.03.2021 issued under Section 148 on the ground that the sanction obtained under Section 151 was invalid. The approval document stated ‘Reasons to Believe-As per Annexure’, but the said annexure was a blank page. The High Court held that this fact, which was not denied by the revenue, was sufficient in itself to prove that the approval was granted mechanically and without application of mind. The Court also rejected a document containing reasons that the revenue subsequently tendered during the hearing, noting that it was not available on the Income Tax Portal, was not referenced in the affidavit-in-reply, and had date discrepancies. Holding the sanction to be invalid, the Court quashed the impugned reassessment notice as being without jurisdiction. (AY. 2017-18)