Reopening Tax Assessment Invalid: "Yes" Notation Insufficient for Approval u/ss 147 and 151 of Income Tax Act.

Reopening of assessment u/s 147 - Valid grant of approval u/s. 151 or not - without application of mind - In our considered view, mere scribbling of "Yes" by the approving authority, as is the case before us, can by no means suffice the statutory obligation cast upon him for granting approval after due application of mind for issuance of notice u/s. 148 of the Act by the AO, as the said statutory check would otherwise be rendered as a mere idle formality, nugatory or in fact nothing better than an eye wash, which would beyond any doubt defeat the very purpose for which the said supervisory jurisdiction of the superior authorities had been made available on the statute by the legislature. - AT .....

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