On writ the Court held that  no enquiry as per S. 148A has been made because if the AO had only made such an enquiry or even bothered to verify the IT Portal relating to the deceased assessee, he would have certainly come to know that the assessee is deceased and had died on 23rd July, 2020. The notice under S. 148A(b) has been issued without making the enquiry as mandated under S.  148A. Therefore, the notice issued under S. 148A(b) itself would be bad in law and has to be quashed and set aside. Approval applied for and granted under S. 151 exposes the total non application of mind by the AO who applied for the approval, the Addl./Jt. CIT who recommended granting of approval and the Principal CIT who granted the approval. Row 9 of the approval form states “time-limit for current proceedings covered under S. 149(1)(b) for more than 3 years but not more than 10 years. The assessment pertains to asst. yr. 2019-20, whereas the notice issued under S.  148A(b) is dt. 29th March, 2023 and, therefore, within the three years period. Taking Row 9 to be correct, then Row 7 indicates the quantum of income which has escaped assessmentRs. 3 lakhs. Therefore, the notice issued under S.  148A(b) itself could not have been issued. If the time-limit for current proceedings is covered under s. 149(1)(b), i.e., for more than 3 years but not more than 10 years, Principal CIT has no power to grant approval and the approval should have been granted by the Principal Chief CIT. In the circumstances, the order dt. 18th April, 2023 under S. 148A(d) and the consequent notice also dt. 18th April, 2023 under S. 148 are  quashed and set aside.  Followed, Dhirendra Bhupendra Sanghvi v. Asstt. CIT  (2023) 151 taxmann.com 541 (Bom) (HC)   (AY.  2020-21)