Mechanical sanction for reassessment reopening invalidates proceedings when the approving authority does not apply independent mind.

Reassessment reopening was invalid because the prescribed authority granted approval mechanically, without independent application of mind. The sanction was only a bare satisfaction note and did not show meaningful consideration of the material, which breached the mandatory requirement for valid reopening. That defect went to the root of the reassessment process and rendered the initiation unsustainable. The Revenue's challenge therefore failed, and the reassessment action was invalid.

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Issues: Whether the reopening of assessment was valid when the prescribed authority accorded approval in a mechanical manner without independent application of mind.

Analysis: The challenge to the reopening was entertained under the appellate procedure, and the validity of the sanction under the reopening provisions was examined. The approval recorded by the prescribed authority as a bare satisfaction note, without demonstrable independent consideration, was treated as non-compliance with the mandatory requirement of meaningful sanction for reopening. The defect went to the root of the reassessment action and rendered the reopening unsustainable.

Conclusion: The reopening was held invalid and the Revenue's challenge failed.

Final Conclusion: The reassessment initiation was invalid, and the Revenue's appeal was dismissed.

Ratio Decidendi: Sanction for reopening must reflect independent application of mind by the prescribed authority, and a mechanical approval vitiates the reassessment proceedings.

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