Invalid sanction under section 151 vitiates reassessment where approval is only "As per Annexure" and not an independent grant.

Approval for reopening under section 151 must reflect an independent application of mind by the sanctioning authority; a mere endorsement such as "As per Annexure" on the Assessing Officer's recorded reasons is not valid sanction in law. Because the approval was only a reference to the annexure and not a separate grant of permission, the reassessment was treated as having been initiated without valid jurisdiction. The reassessment proceedings were therefore vitiated, and the reassessment order was quashed for want of proper approval.

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Issues: Whether the reopening of assessment was valid when the approval under section 151 was recorded only as "As per Annexure", and whether the reassessment order was liable to be quashed for want of valid sanction.

Analysis: The approval sought by the Assessing Officer under section 151 was considered. The sanctioning authority did not record an independent grant of approval and instead merely wrote "As per Annexure". The annexure contained the reasons recorded by the Assessing Officer for reopening the case. On that basis, the approval was held to be no valid approval in law. Reassessment initiated on such defective sanction was treated as an invalid assumption of jurisdiction, which vitiated the entire proceedings.

Conclusion: The reopening was held invalid for want of proper approval under section 151, and the reassessment order was quashed.

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