Assessee-company, engaged in business of air-conditioning and refrigeration, had filed its return and claimed certain amount of expenses towards corporate social responsibility (CSR) as deduction under sections 35AC and 80G. Assessment was completed under section 143(2) read with section 92CA.  After four years, a reopening notice under section 148 was issued after receiving sanction from Additional Commissioner under section 151 of the Act. The objection for reassessment notice and recorded reasons was dismissed. On writ allowing the petition the Court held that except for a general statement in reasons for reopening, Assessing Officer had not disclosed what material facts were not disclosed by assessee.  It was further noted that sub-section (1) of section 151 provides that no notice shall be issued under section 148 by Assessing Officer, after expiry of a period of four years from end of assessment year, unless PCCIT/CCIT/PCIT/CIT was satisfied that reasons of reopening were fit for case. Since four years had expired from end of relevant assessment year, sanction under section 151 could only be granted by PCIT/CIT. Accordingly notice issued with sanction of Additional Commissioner was quashed and  set aside. (AY.  2015-16)