https://www.taxtmi.com/caselaws?id=801176 Section 151 approval for a reassessment notice must reflect independent, meaningful consideration of the material and statutory requirements; merely endorsing the Assessing Officer's reasons or stating that notice is fit for issue is mechanical and insufficient. The sanction requirement operates as a substantive safeguard even where approval is administrative, requiring reasons and application of mind. Conflicting non-jurisdictional High Court views remain unresolved by summary dismissal of special leave petitions, which neither triggers merger nor establishes binding law. Applying the interpretation favourable to the assessee, mechanical approval invalidates the sanction and requires quashing the consequential reassessment. en-us Wed, 30 Sep 2026 00:00:00 +0530 Fri, 16 Oct 2026 05:20:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801176 Section 151 approval for a reassessment notice must reflect independent, meaningful consideration of the material and statutory requirements; merely endorsing the Assessing Officer's reasons or stating that notice is fit for issue is mechanical and insufficient. The sanction requirement operates as a substantive safeguard even where approval is administrative, requiring reasons and application of mind. Conflicting non-jurisdictional High Court views remain unresolved by summary dismissal of special leave petitions, which neither triggers merger nor establishes binding law. Applying the interpretation favourable to the assessee, mechanical approval invalidates the sanction and requires quashing the consequential reassessment. Case-Laws Income Tax Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801176