Reassessment sanction requires consistent escapement figures; reopening fails where the threshold for extended limitation is not met.

Reassessment approval under section 151 must be based on a clear and consistent view of the alleged escapement; where the sanctioning authority and the Assessing Officer proceed on differing figures, the approval can reflect non-application of mind. The text also notes that extended limitation for reopening under section 149(1) depends on the escapement ultimately relied upon crossing the prescribed monetary threshold. Here, the figures moved from Rs. 1,11,37,000 to Rs. 66,13,961 and were finally confined to Rs. 27,00,000, showing inconsistency in the basis for sanction and failure to meet the threshold for extended reopening. The reopening was therefore treated as invalid.

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Issues: Whether the reassessment approval under section 151 and the notice under section 148 were valid when the sanctioning authority and the Assessing Officer proceeded on inconsistent figures of alleged escapement, and whether the reopening could survive where the ultimately sustained escapement was below the monetary threshold prescribed for extended limitation under section 149(1).

Analysis: The approval for reopening was granted on an alleged escapement of Rs. 1,11,37,000/-, but the figure was later reduced in the order under section 148A(d) to Rs. 66,13,961/-, and the final assessment was confined to Rs. 27,00,000/-. This showed that the Assessing Officer was not certain about the true quantum of escapement when sanction was sought. The sanction under section 151 was therefore based on inconsistent and inflated assumptions, reflecting non-application of mind. Since the actual escapement ultimately relied upon was only Rs. 27,00,000/-, the condition for invoking the extended limitation for reopening beyond three years was not satisfied.

Conclusion: The approval under section 151 and the reassessment initiation were held invalid, and the reopening was quashed in favour of the assessee.

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