The court held that the approval granted u/s 151 for reopening the assessment u/s 147 was invalid. The...

The court held that the approval granted u/s 151 for reopening the assessment u/s 147 was invalid. The satisfaction arrived at by the concerned officer should be discernible from the sanction order, but the approval order lacked any reasoning or material that weighed for granting approval. Mere appending the expression "Yes I am satisfied" without any indication of examining the material or thought process is insufficient. The exercise appeared ritualistic and formal rather than meaningful. Reasons are the link between material and conclusion, but no such material was present to conclude that the approving authority considered the reasons assigned by the Assessing Officer. Mere repetition of statutory words or rubber-stamping the letter see..... .....

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