Manual s.151 sanction issued after s.148 notice renders reopening invalid ab initio; assessment quashed despite unsigned online sanction

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....ITAT held that two distinct reasons to reopen assessment were recorded by the AO and separately transmitted for sanction under s.151; the first online sanction lacked the PCIT's signature and contained forwarding/factual irregularities, while the subsequent manual sanction, issued after the s.148 notice, prevailed. The Tribunal found the "rubber-stamp" allegation unfounded as independent reasons existed, but concluded that because the operative manual approval post-dated the issuance of the s.148 notice, the notice was invalid ab initio. Result: reopening of assessment quashed and the s.148 notice held void, with the manual sanction treated as the valid authorization for reopening (subject to temporal invalidity here).....