Mechanical section 151 sanction and lack of jurisdiction invalidated reopening, making the reassessment unsustainable.

A reassessment cannot stand where sanction under section 151 is granted mechanically without real application of mind to the reasons recorded by the Assessing Officer, because such perfunctory approval is invalid. The reopening also failed because the notice under section 148 was issued by an officer who lacked jurisdiction, even though the original return and later transfer showed jurisdiction lay elsewhere. Both defects went to the root of the reassessment, rendering the proceedings unsustainable and the reassessment annulled, while the merits remained untouched.

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Issues: Whether the reassessment proceedings were vitiated by a mechanical approval under section 151 of the Income-tax Act, 1961 and by issuance of the reopening notice by an officer lacking jurisdiction.

Analysis: The reassessment was founded on approval granted under section 151 in a perfunctory manner. The approval did not disclose any meaningful application of mind or recorded satisfaction on the reasons furnished by the Assessing Officer, and was treated as a mere formality. The Tribunal also noted that the original return placed jurisdiction with the Assistant Commissioner of Income Tax, while the notice under section 148 was issued by the Income Tax Officer despite the case later being transferred on the basis that jurisdiction did not lie with that officer. Both defects went to the root of the reassessment.

Conclusion: The approval under section 151 was invalid and the reopening was without valid jurisdiction; the reassessment proceedings were therefore unsustainable.

Final Conclusion: The reassessment was annulled and the assessee's appeal succeeded, leaving the merits untouched.

Ratio Decidendi: For a valid reassessment, the sanctioning authority's approval under section 151 must reflect real and discernible satisfaction based on application of mind, and a reopening notice issued by an officer lacking jurisdiction cannot sustain the reassessment.

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