Valid reassessment sanction upheld where internal business allocation approval was proved without any formal written order requirement.

Reassessment notices under section 148 were upheld because the sanction under section 151(1) was shown to have been validly entrusted to the Member of the Board with the previous approval of the Central Government. The Court treated the allocation of business within the Board as an internal administrative arrangement that did not affect taxpayers' rights, and held that rule 4 of the CBDT (Regulation of Transaction of Business) Rules, 1964 did not require such approval to be recorded in any special or formal order. Office notes and affidavits were sufficient to prove valid approval, so the challenge to the notices on the ground of want of lawful sanction failed.

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Issues: Whether notices for reopening assessments under section 148 of the Income-tax Act, 1961 were invalid for want of valid sanction under section 151(1), and whether approval of the Central Government for allocation of the Board's business under rule 4 of the Central Board of Direct Taxes (Regulation of Transaction of Business) Rules, 1964 had to be recorded by a formal order.

Analysis: The material showed that the proposal to transfer the work of according sanction for reopening assessments from the Chairman to the Member of the Board had been referred to and approved by the competent authority. The Court treated the allocation of business and the approval as matters of internal arrangement which did not affect the assessees' rights, and held that rule 4 did not prescribe any special form in which such approval had to be recorded. The office notes and affidavits sufficiently established that the Member who issued the sanction had been validly entrusted with that function with the previous approval of the Central Government.

Conclusion: The notices under section 148 were not invalid on the ground of want of lawful sanction, and the challenge to their validity on that basis failed.

Ratio Decidendi: Where the competent authority's approval for redistribution of internal business is proved and the governing rule does not require a formal order, the validity of a reassessment sanction cannot be defeated merely because the approval was not separately embodied in a formal written order.

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