Mechanical approval for Section 148 reopening renders reassessment invalid where sanction lacks independent application of mind.

Reassessment under Section 148 was invalid where the approval for issuing notice was recorded in a stereotyped form and showed no independent application of mind to the material before the competent authority. A mechanical or ritualistic sanction was treated as insufficient because valid reopening requires conscious, reasoned satisfaction on the facts placed for approval. On that basis, the notice under Section 148 and the consequential reassessment proceedings were held to be invalid.

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Issues: Whether the approval granted for issuance of notice under Section 148 of the Income-tax Act, 1961 was mechanical and application of mind, rendering the reassessment proceedings invalid.

Analysis: The reassessment was initiated on the basis of approval recorded in a stereotyped form stating that it was a fit case for issue of notice under Section 148. The approval was examined against the requirement that the competent authority must independently apply its mind to the material placed before it before granting sanction for reopening. A mechanical or ritualistic approval was found to be insufficient, and the precedent relied upon supported the view that such approval vitiates the notice and the reassessment founded upon it.

Conclusion: The approval was held to be mechanical and without due application of mind, and the notice under Section 148 and the consequential reassessment proceedings were held to be invalid.

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