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Issues: Whether the reopening approval under section 151 of the Income-tax Act, 1961 was vitiated by mechanical satisfaction, rendering the reassessment invalid.
Analysis: The sanction recorded by the prescribed authority merely stated "yes I am satisfied", which was treated as a mechanical approval rather than an application of mind. The department did not rebut this factual position. In such circumstances, the reopening was held to be bad in law, and the assessment based on it could not be sustained.
Conclusion: The reassessment was invalid for want of proper approval under section 151 of the Income-tax Act, 1961, and the appeal succeeded.
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