High Court held that reassessment proceedings under Section 148 are invalid when the Principal Commissioner grants approval under Section 151 mechanically without independent application of mind
Meetu Kumari | Nov 11, 2025 |
Rajasthan High Court Quashes Reassessment for Mechanical Approval Under Section 151
The petitioner in this case challenged the reassessment proceedings initiated under Section 148 of the Income Tax Act, 1961, for Assessment Year 2017-18. The reassessment notice and assessment order were issued after obtaining “approval” from the Principal Commissioner of Income Tax (Central), Jodhpur.
The petitioner said that the approval granted under Section 151 was mechanical and lacked reasoning, as the PCIT had merely signed the proforma and no reasoning, satisfaction, or application of mind was recorded; such a sanction did not confer validity upon the initiation of reassessment proceedings. The revenue in their defence held that due process was followed and that the approval was granted as per the prescribed procedure.
Main Issue: Whether the reassessment proceedings initiated under Section 148 of the Income Tax Act can go on when the approval under Section 151 was granted mechanically by the Principal Commissioner without satisfaction or application of mind.
HC Held: The Rajasthan High Court held that the sanction granted by the PCIT was mechanical and lacked independent application of mind. The Court relied upon previous Supreme Court decisions, and reiterated that the sanctioning authority must examine the material relied upon by the Assessing Officer and record conscious satisfaction before granting approval under Section 151. The Court examined the sanction form and found that it contained only a standard endorsement, “Yes, I am satisfied”, without any discussion or analysis of material facts or the reasons recorded by the Assessing Officer. This, according to the petitioner, demonstrated complete non-application of mind, rendering the entire reassessment process void ab initio.
Therefore, the Court quashed the approval granted by the Principal Commissioner, as well as the consequent notice issued under Section 148 and all proceedings arising therefrom. It emphasised that the power to reopen assessments must be exercised with due care and independent judgment, not as a mechanical endorsement.
The writ petition was thus allowed.
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