Mechanical approval under section 151 invalidates reassessment reopening for non-application of mind.

Reassessment under section 147 requires valid approval under section 151 as a jurisdictional precondition. Where the prescribed authority grants sanction mechanically, without independent application of mind, the approval is invalid and the reopening cannot stand. The record showed routine endorsement of satisfaction rather than a considered decision, so the reassessment was quashed.

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Issues: Whether reassessment proceedings were valid when the approval under section 151 was granted mechanically.

Analysis: The reopening was challenged on the ground that the prescribed authority had accorded approval in a routine manner by stating satisfaction without independent application of mind. The record showed that the sanction was granted mechanically. In the context of reassessment under section 147, a valid approval under section 151 is a jurisdictional requirement, and a non-application of mind in granting such approval invalidates the reopening.

Conclusion: The reopening was quashed as the approval under section 151 was mechanical and invalid.

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