https://www.taxtmi.com/caselaws?id=469097 Reassessment initiated beyond four years required prior sanction under section 151(1), and the approval was invalid because the sanctioning authority acted mechanically without applying its mind to the recorded reasons and material. The proposal contained incorrect statutory references, showed no meaningful consideration of the basis for reopening, and was merely endorsed as a fit case for notice under section 148. The settled safeguard under section 151 is not a formality; it demands objective satisfaction on the material before the competent authority. As the approval was ritualistic and not independently considered, the reassessment was held invalid and the reopening was quashed. en-us Wed, 28 Oct 2020 00:00:00 +0530 Tue, 02 Jun 2026 15:38:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469097 Reassessment initiated beyond four years required prior sanction under section 151(1), and the approval was invalid because the sanctioning authority acted mechanically without applying its mind to the recorded reasons and material. The proposal contained incorrect statutory references, showed no meaningful consideration of the basis for reopening, and was merely endorsed as a fit case for notice under section 148. The settled safeguard under section 151 is not a formality; it demands objective satisfaction on the material before the competent authority. As the approval was ritualistic and not independently considered, the reassessment was held invalid and the reopening was quashed. Case-Laws Income Tax Wed, 28 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469097