Mechanical section 151 approval invalidated reassessment where sanction lacked real application of mind

Reassessment under section 147 requires a valid sanction under section 151 based on real satisfaction by the specified authority. Where the approval is only a bare endorsement, with no discernible reasons or independent consideration of the material before the authority, the safeguard becomes mechanical rather than meaningful. On these facts, the jurisdictional basis for reopening was found defective, and the reassessment was held invalid for want of proper approval.

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Issues: Whether reassessment initiated under section 147 was invalid because the approval under section 151 was granted mechanically and without application of mind.

Analysis: The approval recorded by the specified authority was a bare endorsement without discernible reasons or independent consideration of the material placed before it. The governing legal framework requires the sanctioning authority to be satisfied on the basis of the reasons recorded by the Assessing Officer, and such satisfaction must be a meaningful safeguard rather than a ritualistic formality. Since the approval did not reflect real application of mind, the jurisdictional foundation for reopening was defective.

Conclusion: The reassessment was held to be invalid for want of a valid approval under section 151, and the challenge to jurisdiction succeeded in favour of the assessee.

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