The AO issued a notice under Section 148A(b), passed an order under Section 148A(d), and issued a notice under Section 148. The assessee filed a writ petition contending that there was a total non-application of mind in granting approval under Section 151. Further, the AO refused to grant a personal hearing to the assessee, citing that it was premature and would be provided during the subsequent proceedings. The Court observed that the notice under Section 148A(b) was issued for AY 2019-20, which falls within the 3-year time limit. However, the application submitted for approval and sanction under Section 151 incorrectly stated that the ‘Time limit for current proceedings covered under section 149(1)(b)-for more than 3 years but not more than 10 years’. Consequently, the Court held that the application for approval, the recommendation, and the subsequent grant of approval were all mechanically made by the officers without proper application of mind. The Hon’ble Supreme Court noted a delay of 201 days in filing the Special Leave Petition, which did not contain any satisfactory reasons for the condonation of the delay. Hence, the Hon’ble Supreme Court dismissed the SLP  as the  reasons assigned for seeking condonation of delay of 201 days in filing the SLP  are neither satisfactory nor sufficient in law to condone the same.-(AY 2019-20)