Mechanical sanction for reassessment invalidates jurisdiction where approval lacks real application of mind.

Reassessment sanction under section 151 was held invalid where the approval proforma wrongly referred to section 147(b), a provision no longer in force, and the sanctioning authority recorded only perfunctory, mechanical satisfaction on a standard format. The absence of meaningful application of mind rendered the approval ritualistic and vitiated the assumption of jurisdiction for reassessment. The jurisdictional objection was therefore accepted, and the reassessment proceedings were quashed in favour of the assessee.

---

---

Issues: Whether the reassessment proceedings were invalid for want of proper sanction and due application of mind under section 151, including the erroneous reference to section 147(b) in the approval process.

Analysis: The approval proforma referred to section 147(b), although that provision had ceased to exist. The sanctioning authority recorded only a perfunctory satisfaction on a standard format, without meaningful application of mind. Such an approval was treated as mechanical and ritualistic, vitiating the assumption of jurisdiction for reassessment.

Conclusion: The reassessment proceedings were quashed and the jurisdictional challenge was accepted in favour of the assessee.

---