Mechanical sanction for reopening invalidates reassessment where approval shows no real application of mind.

Sanction for reassessment under section 151 must reflect a real application of mind to the recorded reasons; a cryptic approval such as "yes. I am satisfied" was treated as mechanical and therefore invalid. On that basis, the reopening could not be sustained and the reassessment was quashed. The other grounds did not survive once the sanction for reopening was held defective.

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Issues: Whether the reassessment proceedings were valid when the approval under section 151 of the Income-tax Act, 1961 was granted mechanically.

Analysis: The approval recorded as "yes. I am satisfied" was treated as a mechanical exercise and not a meaningful application of mind to the reopening reasons. In view of the settled requirement that sanction for reopening must be granted on due consideration, the reassessment could not be sustained. The remaining grounds were rendered academic.

Conclusion: The reopening was invalid and the assessment was quashed in favour of the assessee.

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