Independent sanction under section 151 is essential for reassessment; a mechanical approval vitiates the reopening proceedings.

Sanction under section 151 for issuing a notice under section 148 must reflect independent application of mind by the specified authority. Where the approval merely endorses the Assessing Officer's satisfaction note, without recording separate reasoning or consideration of the material, the sanction is mechanical and invalid. On that basis, the reassessment notice and all consequential proceedings were quashed, as the foundation for reopening failed for want of valid approval.

---

---

Issues: Whether approval granted under section 151 for issuance of notice under section 148 was mechanical and without independent application of mind, and whether the subsequent reassessment proceedings could survive.

Analysis: The approval recorded only that, on going through the satisfaction note and the comments of the Assessing Officer and Range Head, it was a fit case for issuance of notice under section 148. No independent reasoning, consideration of the material, or indication of separate satisfaction by the specified authority was recorded. Since sanction under section 151 requires an informed and independent decision by the higher authority, a mere endorsement of the Assessing Officer's view does not satisfy the statutory requirement.

Conclusion: The approval under section 151 was held to be mechanical, arbitrary, and invalid, with the result that the notice and all consequential proceedings were quashed in favour of the assessee.

Final Conclusion: The reassessment foundation having failed for want of valid sanction, the appeal succeeded and the impugned proceedings were annulled.

Ratio Decidendi: Sanction under section 151 must reflect independent application of mind by the specified authority; a mechanical endorsement of the Assessing Officer's recommendation vitiates the reassessment jurisdiction and renders the consequential proceedings invalid.

---