Mechanical sanction for reassessment reopening invalidates approval when statutory mind application under section 151 is absent.

Reassessment reopening under sections 147 and 148 is invalid where the statutory sanction under section 151 is granted mechanically without application of mind. The prescribed authority must apply meaningful consideration to the Assessing Officer's recorded reasons before approving reopening; a perfunctory approval does not satisfy the requirement of valid authorisation. On that basis, the reopening was quashed for want of proper sanction, and relief was granted to the assessee.

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Issues: Whether the reassessment reopening under sections 147 and 148 was valid when the sanction under section 151 was granted mechanically without application of mind.

Analysis: The reopening was challenged on the ground that the prescribed authority accorded approval to the reasons recorded by the Assessing Officer in a mechanical manner. The absence of meaningful consideration in the sanction process was treated as a fundamental defect going to the validity of the reopening proceedings.

Conclusion: The reopening was held invalid and was quashed for want of proper sanction under section 151. The appeal was allowed in favour of the assessee.

Ratio Decidendi: A reassessment reopening is unsustainable where the statutory sanction is granted mechanically without application of mind, as such approval does not satisfy the requirement of valid authorization under section 151.

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