Reassessment sanction under Section 151 must show recorded satisfaction; a bare "Approved" endorsement is mechanically invalid.

Approval for reassessment under Section 151 of the Income-tax Act, 1961 must show application of mind and recorded satisfaction, even if brief; a bare endorsement such as "Approved" is a mechanical, non-speaking exercise and does not satisfy the statutory safeguard. Because the sanction did not disclose any consideration of the matter, it was invalid and the reassessment foundation failed, resulting in relief to the assessee.

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Issues: Whether approval granted under Section 151 of the Income-tax Act, 1961, by merely recording the word "Approved" without reasons or satisfaction, was valid.

Analysis: Section 151 requires the competent authority to apply mind and record satisfaction, even if briefly, before authorising reassessment. A bare endorsement of "Approved" does not disclose any consideration of the matter and amounts to a ritualistic and mechanical exercise. Such an approval fails the statutory safeguard built into the provision and cannot sustain the reassessment proceedings.

Conclusion: The approval was invalid, granted in a mechanical and non-speaking manner, and was rightly quashed in favour of the assessee.

Final Conclusion: The reassessment foundation failed for want of valid sanction, and the appeal succeeded.

Ratio Decidendi: Approval under Section 151 of the Income-tax Act, 1961, must reflect application of mind and recorded satisfaction, however brief; a mere endorsement of "Approved" is insufficient and renders the sanction invalid.

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