Valid prior sanction for reassessment is mandatory; absent section 151 approval, the notice and reassessment fail.

A reassessment initiated under section 148 was held without jurisdiction where the purported sanction under section 151 was neither manually signed nor digitally signed. The Tribunal accepted that valid prior approval is a mandatory precondition for a reassessment notice and followed coordinate Bench authority that a notice issued without such sanction is invalid. On verification of the record, the absence of a valid approval vitiated the initiation itself, and the reassessment order was quashed as bad in law.

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Issues: Whether reassessment proceedings and the resulting assessment were without jurisdiction because the approval under section 151 was neither manually signed nor digitally signed, and whether the reassessment order was liable to be quashed.

Analysis: The assessment was framed under section 147 read with section 144B on the basis of notice under section 148. The Tribunal found, on verification of the assessment records, that the approval purportedly granted under section 151 was neither manually signed nor digitally signed. The Tribunal followed the coordinate Bench view that a notice under section 148 issued without a valid prior sanction under section 151 is without jurisdiction, and held that the absence of a valid approval vitiated the reassessment initiation.

Conclusion: The reassessment order was held to be bad in law and was quashed.

Final Conclusion: The assessee succeeded on the jurisdictional challenge to reassessment, and the appeal was allowed.

Ratio Decidendi: A notice under section 148 and the consequent reassessment are invalid where the statutory sanction under section 151 is not validly granted before initiation of the proceedings.

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