Held that, according to section 151, no notice under section 148 shall be issued beyond a period of four years unless the Principal Commissioner or Chief Commissioner or the Commissioner was so satisfied. However, the notice under section 148 was issued beyond the period of four years with the sanction or approval, not of the Principal Commissioner or Commissioner, but of the Additional Commissioner. As a result, the issue of notice under section 148 and the consequent assessment order passed were invalid, illegal and liable to be quashed. Tribunal also held that  the records showed that the Principal Commissioner had given one consolidated approval in the case of 56 different assessees in one shot through one letter which was not even signed by him but by the ITO, who was not a competent authority to sign, or give, the approval. Further, there was a doubt whether the approval had been received before the issue of notice under section 148. In terms of section 151 such an approval could not be given to as many as 56 assessees in a single document as each assessee’s case was independent and separate and called for different reasons to be recorded. The procedure and way of approval and satisfaction were not proper and made without application of mind in a slipshod manner. Therefore, the reopening of the assessment was not sustainable as there were clear irregularities and violation of section 151; the very foundation of the issue of notice under section 148 was not in terms of the law. The proceedings under section 147 were to be quashed. (AY. 2008-09, 2009-10)