Mechanical sanction for reopening vitiates reassessment where approval lacks independent application of mind and proper consideration.

Reassessment proceedings are invalid where sanction for reopening is granted mechanically without independent application of mind. On the facts described, the reopening was initiated on information from the Investigation Wing, but the Addl. CIT's approval was found to be mechanical and lacking proper consideration of the material. That defect vitiated the reassessment process, and the reopening was held unsustainable in law. The reassessment was accordingly quashed in favour of the assessee. The stated principle is that sanction for reopening under reassessment provisions must reflect genuine, independent application of mind.

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Issues: Whether the reassessment proceedings were valid where the approval for reopening was granted mechanically without independent application of mind.

Analysis: The reassessment was initiated on the basis of information from the Investigation Wing. The approval accorded by the Addl. CIT was found to be mechanical, and the reopening was held to suffer from lack of proper application of mind. On that basis, the reassessment proceedings were treated as unsustainable in law.

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

Ratio Decidendi: Sanction for reopening under reassessment provisions must reflect independent application of mind; a mechanical approval vitiates the reassessment proceedings.

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