On writ allowing the petition the Court held that the application for approval, recommendation and the grant of approval under section 151 had all been made by the authorities mechanically and without application of mind. In the form submitted for approval under section 151, for issue of notice under section 148, in row 9, it was mentioned “time limit for current proceedings covered under section 149(1)(b) for more than three years but not more than ten years” and row 22 stated that the approval had been granted by Principal Commissioner. In the form in row 16 “whether personal hearing was requested by the assessee”, the answer was shown as “No”. In respect of rows 9 and 22, there had been non-application of mind by the Assessing Officer seeking approval, the Additional or Joint Commissioner who had recommended it was a fit case and the Principal Commissioner who had granted approval because the time limit for the reassessment proceedings under section 147 should be covered under section 149(1)(a), i. e., for less than three years because the assessment year was 2019-20 and the notice issued under section 148A(b) was dated March 28, 2023. Non-application of mind even by the authority, who had filed the affidavit-in-reply. The order passed under section 148A(d) and the notice issued under section 148 were quashed and set aside.(AY.2019-20)