https://www.taxtmi.com/caselaws?id=791334 A reassessment cannot stand where sanction under section 151 is granted mechanically without real application of mind to the reasons recorded by the Assessing Officer, because such perfunctory approval is invalid. The reopening also failed because the notice under section 148 was issued by an officer who lacked jurisdiction, even though the original return and later transfer showed jurisdiction lay elsewhere. Both defects went to the root of the reassessment, rendering the proceedings unsustainable and the reassessment annulled, while the merits remained untouched. en-us Fri, 27 Mar 2026 00:00:00 +0530 Sat, 09 May 2026 07:13:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791334 A reassessment cannot stand where sanction under section 151 is granted mechanically without real application of mind to the reasons recorded by the Assessing Officer, because such perfunctory approval is invalid. The reopening also failed because the notice under section 148 was issued by an officer who lacked jurisdiction, even though the original return and later transfer showed jurisdiction lay elsewhere. Both defects went to the root of the reassessment, rendering the proceedings unsustainable and the reassessment annulled, while the merits remained untouched. Case-Laws Income Tax Fri, 27 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791334