Valid sanction for reassessment notices is essential; wrong statutory approval invalidates the notice and all consequential assessment orders.

Reassessment notices must be supported by valid sanction under the correct clause before they can sustain further proceedings. Here, sanction was obtained under the wrong clause of Section 151 of the Income-tax Act, so it was treated as invalid; the notice founded on that sanction could not survive, and the consequential assessment orders also fell with it. The notices and all resulting orders were quashed in favour of the assessee.

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Issues: Whether the notices and consequential assessment orders were liable to be quashed for want of proper sanction under Section 151 of the Income-tax Act, 1961.

Analysis: The petition was held to be covered by the earlier decision on the requirement of sanction for the relevant assessment year. Since the sanction had been obtained under the incorrect clause of Section 151, the sanction was treated as invalid. Once the sanction was invalid, the notice founded on it could not survive, and any assessment order passed in consequence of such notice was also liable to fall.

Conclusion: The notices and all consequential orders were quashed and set aside in favour of the assessee.

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