Independent application of mind for reassessment sanction is essential; omnibus approval made the reopening and reassessment invalid.

ITAT Delhi held that sanction for reassessment under section 151 must reflect independent application of mind to each assessee's case. A consolidated, omnibus approval for 111 cases, without case-specific consideration of the material, was treated as mechanical and contrary to the statutory safeguard. Because the reopening rested on that invalid approval, the notice under section 148 was without jurisdiction and the reassessment proceedings could not survive. The reassessment was therefore quashed in favour of the assessee.

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Issues: Whether the common approval granted by the Principal Commissioner for 111 reassessment cases satisfied the requirement of independent application of mind under section 151 of the Income-tax Act, 1961, and whether the notice under section 148 and the consequential reassessment were valid.

Analysis: The approval was granted in a consolidated manner for multiple cases without case-specific satisfaction. The Tribunal followed the jurisdictional High Court's view that sanction for reopening is not a ritualistic formality and must reflect independent consideration of the material relating to each assessee. A common omnibus approval, without any indication of individual examination, was held to be mechanical and contrary to the statutory safeguard built into section 151. Since the reopening was founded on that invalid approval, the notice issued under section 148 could not survive and the reassessment proceedings were vitiated.

Conclusion: The approval under section 151 was invalid, the notice under section 148 was without jurisdiction, and the reassessment was quashed in favour of the assessee.

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