Unsigned section 151 sanction invalidates reopening, making reassessment without jurisdiction and deleting the addition.

Reassessment under sections 147 and 148 requires valid sanction under section 151, and that approval must bear a manual or digital signature as a mandatory safeguard. Where the approval on record was issued electronically but carried neither a manual signature nor a digital signature certificate, the sanction was invalid and could not support reopening. The reassessment initiated on that basis therefore lacked jurisdiction and was quashed. Since the reassessment failed at the threshold, the merits of the addition were not examined and the addition was deleted in favour of the assessee.

---

---

Issues: Whether reassessment proceedings under sections 147 and 148 were valid when the approval under section 151 was neither manually nor digitally signed.

Analysis: The reassessment was founded on approval under section 151 granted electronically. The approval produced on record contained no manual signature and no digital signature certificate. The Tribunal held that signature on such approval is a mandatory safeguard, whether the document is issued physically or electronically. An unsigned approval does not constitute valid sanction for reopening, and the reassessment initiated on that basis fails for want of jurisdiction. As the reassessment was quashed, the merits of the addition did not require adjudication.

Conclusion: The reassessment proceedings were invalid and were quashed, and the addition was deleted in favour of the assessee.

---