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Reopening of assessment u/s 147 was invalid due to lack of valid sanction as required u/s 151. The competent authority must independently apply its mind based on material before granting approval/sanction, which is not an empty formality. The approval granted for 111 reassessment cases through a general order, without referring to any specific material or case details, does not fulfill the requirement of meaningful application of mind. The sanction order lacks any reference to the material of the present case. Mere ritualistic or formal approval without recording satisfaction after due application of mind is inadequate. Consequently, the approval granted by the Principal Commissioner of Income Tax for action u/ss 147/148 is invalid, rendering the impugned notice u/s 148 and subsequent proceedings null and void. The matter was decided in favor of the assessee.
Reopening of assessment u/s 147 was invalid due to lack of valid sanction as required u/s 151. The competent authority must independently apply its mind based on material before granting approval/sanction, which is not an empty formality. The approval granted for 111 reassessment cases through a general order, without referring to any specific material or case details, does not fulfill the requirement of meaningful application of mind. The sanction order lacks any reference to the material of the present case. Mere ritualistic or formal approval without recording satisfaction after due application of mind is inadequate. Consequently, the approval granted by the Principal Commissioner of Income Tax for action u/ss 147/148 is invalid, rendering the impugned notice u/s 148 and subsequent proceedings null and void. The matter was decided in favor of the assessee.
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