https://www.taxtmi.com/caselaws?id=469011 Reassessment under Section 148 was invalid where the approval for issuing notice was recorded in a stereotyped form and showed no independent application of mind to the material before the competent authority. A mechanical or ritualistic sanction was treated as insufficient because valid reopening requires conscious, reasoned satisfaction on the facts placed for approval. On that basis, the notice under Section 148 and the consequential reassessment proceedings were held to be invalid. en-us Tue, 30 Sep 2025 00:00:00 +0530 Fri, 29 May 2026 13:26:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469011 Reassessment under Section 148 was invalid where the approval for issuing notice was recorded in a stereotyped form and showed no independent application of mind to the material before the competent authority. A mechanical or ritualistic sanction was treated as insufficient because valid reopening requires conscious, reasoned satisfaction on the facts placed for approval. On that basis, the notice under Section 148 and the consequential reassessment proceedings were held to be invalid. Case-Laws Income Tax Tue, 30 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469011