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Section 151 sanction for reassessment requires meaningful, independent application of mind; a bare endorsement that notice is fit to issue on the Assessing Officer's recorded reasons is mechanical and invalid. This statutory safeguard applies even if sanction is administrative, because reasons must demonstrate the approving authority's consideration. Conflicting non-jurisdictional High Court views remain independently persuasive where related special leave petitions were summarily dismissed, since neither merger nor binding law under Article 141 follows. The assessee-favourable construction was applied, invalidating the sanction and quashing the reassessment while other grounds remained open.
Section 151 sanction for reassessment requires meaningful, independent application of mind; a bare endorsement that notice is fit to issue on the Assessing Officer's recorded reasons is mechanical and invalid. This statutory safeguard applies even if sanction is administrative, because reasons must demonstrate the approving authority's consideration. Conflicting non-jurisdictional High Court views remain independently persuasive where related special leave petitions were summarily dismissed, since neither merger nor binding law under Article 141 follows. The assessee-favourable construction was applied, invalidating the sanction and quashing the reassessment while other grounds remained open.
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TaxTMI 
TaxTMI 
