Prior approval before reassessment is mandatory; a later digital signature cannot cure a jurisdictional defect.

Valid prior satisfaction by the competent authority is required before reassessment can be initiated, and the approval must be a conscious sanction recorded in the manner known to law. A later digital signature cannot cure the jurisdictional defect where notice under section 148 is issued without lawful prior approval under section 151. On that basis, the reassessment was held invalid and quashed. Because the revision order under section 263 depended entirely on the reassessment, it also could not survive once the foundational reassessment was treated as void ab initio, and it was likewise quashed.

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Issues: (i) Whether reassessment under section 148 of the Income-tax Act, 1961 was valid when the approval under section 151 was not recorded by the competent authority in a lawful and prior manner; (ii) Whether the revision order under section 263 could survive after the reassessment was held void.

Issue (i): Whether reassessment under section 148 of the Income-tax Act, 1961 was valid when the approval under section 151 was not recorded by the competent authority in a lawful and prior manner.

Analysis: The statutory scheme required the competent authority to record satisfaction under section 151 before the Assessing Officer could assume jurisdiction and issue notice under section 148. The approval had to be a real and conscious sanction, not a mechanical formality. The Tribunal held that the satisfaction was not validly recorded in the manner known to law at the time the notice was issued, and that a later digital signature could not cure the jurisdictional defect. The approval was therefore treated as lacking the necessary legal foundation for reopening.

Conclusion: The reassessment proceedings were invalid and were quashed.

Issue (ii): Whether the revision order under section 263 could survive after the reassessment was held void.

Analysis: The revision proceedings were founded on the reassessment order. Once the reassessment itself was quashed as void ab initio, the foundation for revisional action disappeared. A consequential order cannot stand independently when the primary order on which it rests has no legal existence.

Conclusion: The revision order under section 263 also failed and was quashed.

Final Conclusion: The appeals were allowed and the reassessment as well as the consequential revision action were set aside, leaving no surviving assessment order against the assessee.

Ratio Decidendi: Jurisdiction to reopen an assessment arises only after valid prior satisfaction by the competent authority under section 151, recorded with application of mind; where that safeguard is absent, the reassessment notice is without jurisdiction and any consequential proceeding falls with it.

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