The assessee is in the business of jewellery and bullion trade where as in the reasons recorded it is alleged that the assessee has failed to disclose truly and fully all material facts  relevant to “salary” of which income chargeable to tax had escaped assessment.  On writ allowing the petition, the Court held that   the notice having been issued after the expiry of four years from the end of the relevant AY, satisfaction of the Commissioner based on the reasons recorded by the Assessing Officer that it was a fit case for issue of notice under section 148 was mandatory. Sanction of the Commissioner as prescribed under section 151 had not been obtained satisfactorily before issuance of notice under section 148. The contradictions or errors in the reasons recorded were not typographical errors. The Assessing Officer had not applied his mind after drafting the reasons or before forwarding them to the Commissioner for consideration. If the Commissioner had read the reasons he would have noted the errors or contradictions. Satisfaction had been endorsed mechanically without even reading the reasons. Therefore, the notice issued under section 148 was quashed and set aside. (AY.  2012-13)