Invalid reassessment approval without DIN or signature renders reopening without jurisdiction and defeats consequential penalty.

Reassessment proceedings under section 147/148 were held invalid because the prior approval under section 151 was unsigned and lacked a DIN, so the jurisdictional precondition for issuing notice was not satisfied. The defect was treated as substantive and going to the root of the Assessing Officer's authority, making the reassessment notice and resulting assessment without jurisdiction and liable to be quashed. Once the reassessment failed, the consequential penalty under section 271(1)(b) also could not survive.

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Issues: Whether reassessment proceedings initiated under section 147/148 were valid when the approval under section 151 was unsigned and without a DIN, thereby rendering the reassessment order without jurisdiction.

Analysis: The record showed that the sanction/approval under section 151 was not signed and did not carry a DIN number. Since prior sanction from the prescribed authority is a jurisdictional precondition for issuing notice under section 148, the absence of a valid approval meant that the Assessing Officer lacked authority to reopen the assessment. The defect was not a mere procedural irregularity but went to the root of jurisdiction. The consequential penalty under section 271(1)(b) also could not survive once the reassessment itself was set aside.

Conclusion: The reassessment notice and the resulting assessment were invalid and quashed, and the consequential penalty also failed.

Final Conclusion: The proceedings could not be sustained because the statutory precondition for reopening was not satisfied, with the result that the assessee obtained complete relief in the appeal.

Ratio Decidendi: A notice for reassessment issued without a valid sanction under section 151 is without jurisdiction, and the reassessment founded on such notice cannot stand.

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