https://www.taxtmi.com/caselaws?id=789481 ITAT Delhi held that sanction for reassessment under section 151 must reflect independent application of mind to each assessee's case. A consolidated, omnibus approval for 111 cases, without case-specific consideration of the material, was treated as mechanical and contrary to the statutory safeguard. Because the reopening rested on that invalid approval, the notice under section 148 was without jurisdiction and the reassessment proceedings could not survive. The reassessment was therefore quashed in favour of the assessee. en-us Fri, 06 Mar 2026 00:00:00 +0530 Thu, 09 Apr 2026 08:09:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789481 ITAT Delhi held that sanction for reassessment under section 151 must reflect independent application of mind to each assessee's case. A consolidated, omnibus approval for 111 cases, without case-specific consideration of the material, was treated as mechanical and contrary to the statutory safeguard. Because the reopening rested on that invalid approval, the notice under section 148 was without jurisdiction and the reassessment proceedings could not survive. The reassessment was therefore quashed in favour of the assessee. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789481