Mechanical sanction invalidates reassessment reopening where approval lacks application of mind under the Income-tax Act.

Mechanical sanction under section 151 vitiates reassessment reopening under sections 147 and 144 of the Income-tax Act, 1961, because valid initiation requires informed application of mind by the prescribed authority. Where the approval is reduced to a stereotyped endorsement such as "Yes, I am satisfied," the foundational sanction is defective and the reopening cannot stand. On this reasoning, the reassessment proceedings were quashed and the assessee succeeded; the merits became academic once valid sanction was found absent.

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Issues: Whether the reassessment reopening was valid where the prescribed authority granted approval mechanically under section 151 of the Income-tax Act, 1961.

Analysis: The reopening had been initiated under sections 147 and 144 of the Income-tax Act, 1961, and its validity depended on a proper sanction under section 151 of the Income-tax Act, 1961. The record showed that the prescribed authority merely endorsed the proposal with a stereotyped "Yes, I am satisfied" approval. Such mechanical sanction does not amount to the informed application of mind required for valid reopening, and therefore the foundational approval itself was defective.

Conclusion: The reopening was invalid and the reassessment proceedings were quashed in favour of the assessee.

Final Conclusion: The appeal succeeded because the reassessment initiation failed for want of valid sanction, rendering the other merits academic.

Ratio Decidendi: A reassessment reopening is vitiated where the statutory sanction is granted mechanically without proper application of mind.

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