https://www.taxtmi.com/caselaws?id=788514 Reassessment under the Income-tax Act requires valid sanction for issue of notice, and a mere formal or mechanical approval under the approval provision does not satisfy the statutory safeguard. The article applies the principle that where conflicting non-jurisdictional High Court views exist, the interpretation favourable to the assessee must be adopted. On the stated facts, the approving authority's brief endorsement showed no real application of mind, so the sanction was treated as mechanical. That defective approval vitiated jurisdiction for reopening, and the reassessment proceedings were held unsustainable and quashed in favour of the assessee. en-us Fri, 20 Mar 2026 00:00:00 +0530 Tue, 24 Mar 2026 08:12:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788514 Reassessment under the Income-tax Act requires valid sanction for issue of notice, and a mere formal or mechanical approval under the approval provision does not satisfy the statutory safeguard. The article applies the principle that where conflicting non-jurisdictional High Court views exist, the interpretation favourable to the assessee must be adopted. On the stated facts, the approving authority's brief endorsement showed no real application of mind, so the sanction was treated as mechanical. That defective approval vitiated jurisdiction for reopening, and the reassessment proceedings were held unsustainable and quashed in favour of the assessee. Case-Laws Income Tax Fri, 20 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788514