Prior sanction for reassessment notices is mandatory; post-facto approval cannot cure a jurisdictional defect.

Prior satisfaction of the prescribed authority under section 151 is a statutory precondition to issuing a reassessment notice under section 148; if that approval exists only after the notice, the notice is jurisdictionally defective. Section 282A and Rule 127A govern authentication of notices and documents, but they do not cure the absence of prior sanction required before the Assessing Officer assumes jurisdiction. A later unsigned or digitally signed approval cannot retrospectively validate a notice issued without the requisite authority. The reassessment proceedings founded on such notices were therefore treated as without jurisdiction, except where satisfaction and issuance were found to be simultaneous.

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Issues: Whether a notice under section 148 of the Income-tax Act, 1961 was valid when the prescribed authority's satisfaction under section 151 was recorded only after the notice had already been issued, and whether an unsigned or later digitally signed approval could validate the assumption of jurisdiction.

Analysis: Section 151 makes prior satisfaction of the prescribed authority a precondition for issuance of a notice under section 148. Section 282A and Rule 127A deal with authentication of notices and other documents, but they do not dispense with the statutory requirement that the approval under section 151 must exist before the Assessing Officer assumes jurisdiction. The word used in section 282A is mandatory, and the statutory scheme requires the approval to be recorded by the competent authority before the jurisdictional notice is issued. A satisfaction entered after issuance of the notice cannot retrospectively cure the absence of jurisdiction at the time the notice was issued. The Court therefore answered the referred questions against the revenue insofar as the notices were issued before valid approval under section 151.

Conclusion: The notices issued under section 148, and the consequential reassessment proceedings based on them, were held to be without jurisdiction where prior satisfaction under section 151 was absent at the time of issuance. The writ petitions, except the one involving simultaneous recording of satisfaction and issuance of notice, were allowed.

Final Conclusion: Post-facto approval could not validate jurisdictional notices issued without the prior sanction required by the statute, and the consequential reassessment proceedings founded on such notices were quashed, save in the matter where the Court found simultaneous satisfaction and issuance.

Ratio Decidendi: For a reassessment notice under section 148, the statutory sanction under section 151 must be recorded by the competent authority before the notice is issued; later authentication or digital signing does not cure the initial jurisdictional defect.

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