Allowing the petition the Court held that the  Assistant Commissioner had dropped the proceedings pertaining to the assessment year 2016-17, while for the assessment year 2015-16 he had opted to proceed further under section 148A. The decision taken for the assessment year 2016-17 was a reasoned decision, based on the analysis of material on record, but the decision taken subsequently for the assessment year 2015-16 was not only just completely inconsistent with the earlier view but even without reason. Though sanction under section 151 was accorded by two different sanctioning authorities the satisfactions recorded in both orders were of the same Assistant Commissioner. There was nothing on record to suggest that the latter sanctioning authority for the assessment year 2015-16 was apprised of the earlier view taken by the sanctioning authority for the assessment year 2016-17. An assessee deals with the Department as a whole. The order under section 148A(d) and the notice under section 148 were set aside. (AY.2015-16)