The reopening of the assessment was challenged on the ground that sanction was granted by Addl. CIT and not PCIT. Allowing the petition the Court held that the Assessing Officer has to record the reason which has to be final and it cannot be draft submission. Sanction cannot be given mechanically. In the reference to recorded reasons pertains to another entity by the name Laxi Organic, which shows non application of mind. Notice was set aside.