The assessee contended that the reopening pertained to the Assessment Year 2019-20 and the approval was requested on April 12, 2023, it fell within three years. Consequently, section 149(1)(a) applies, not section 149(1)(b) of the Act. Allowing the petition the Court held that there is non-application of mind inasmuch as the affiant admits that while issuing notice for reopening of assessment proceedings under section 148, the Principal Chief Commissioner or Principal Director General and where there is no Principal Chief Commissioner or Principal Director General, then Chief Commissioner or Director General has to grant the sanction if more than three years have elapsed from the end of the relevant assessment year. If that is so, there is no explanation as to how the Pr. Commissioner granted this sanction when in box 9 of the approval the time limit for current proceedings covered under is stated to be under section 149(1)(b)  for more than 3 years but not more than 10 years. In the affidavit in reply, it is stated that the reopening is within three years and the specified authority is Pr. Commissioner under section 151. In that case, the applicable provision would be section 149(1)(a) and not section 149(1)(b). Therefore, it is rather clear that neither the issuing authority, i.e. the Assistant Commissioner, nor the sanctioning authority, i.e., Pr. Commissioner have applied their mind but have simply issued the notice mechanically. Accordingly the notice and order is quashed and set aside. (AY. 2019-20)