Reassessment reopening must rest on specific, verified reasons and proper sanction; vague reasons make the notice unsustainable.

Reassessment under the Income-tax Act was treated as invalid where the recorded reasons for reopening were vague, factually incorrect, and unsupported by tangible material. The ITAT noted the absence of a date, clear property details, identification of the buyer, verification of the sale deed, and proper quantification of escapement, so no live nexus existed between the material and the belief that income had escaped assessment. The sanction under section 151 was also found unsustainable because the reopening, being beyond four years, required informed approval with due application of mind. The reassessment proceedings were quashed, and the consequential assessment became academic.

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Issues: Whether the reassessment proceedings initiated under section 147 read with section 148 of the Income-tax Act, 1961 were valid in law in view of the alleged absence of proper reasons, lack of tangible material, non-application of mind, and defective sanction under section 151 of the Income-tax Act, 1961.

Analysis: The reasons recorded for reopening were found to be vague and factually incorrect, with no date, no clear description of the property, no identification of the buyer, no verification of the sale deed, and no proper quantification of escapement of income. The recorded reasons did not disclose a live link between the material available and the formation of belief that income had escaped assessment. The sanction was also treated as unsustainable because the reopening, being beyond four years, required proper and informed approval, which was not shown to have been granted with due application of mind. Once the foundation for reopening was invalid, the consequential assessment and all other issues became academic.

Conclusion: The reassessment proceedings were quashed as invalid, and the reopening was held to be unsustainable in law.

Ratio Decidendi: Reassessment under section 147 of the Income-tax Act, 1961 must rest on valid, specific, and factually correct reasons supported by a live nexus with the material relied upon, and where those reasons are vague or mechanically approved, the reopening is void.

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