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“sanction under section 151”

ReassessmentSection 151Section 151259 judgments

The decision most relied on for sanction under section 151 is CIT v. Kelvinator of India Ltd. (256 ITR 1), cited in 439 judgments on BharatTax.

Leading authorities on sanction under section 151

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

Chhugamal Rajpal v. S.P. Chaliha
79 ITR 603 · 1971 · Supreme Court
363
citing judgments

A valid reassessment under Section 147 requires concrete 'reasons to believe' that income has escaped assessment, not mere suspicion or a desire to conduct fishing and roving enquiries. If the first proviso to Section 147 applies, there must be a specific finding of the assessee's failure to disclose material facts, not just a mere charge of bogus expenses.

CIT v. S. Goyanka Lime & Chemical Ltd.
64 Taxmann.com 313 · 2015 · Supreme Court
340
citing judgments

A mechanical approval by the prescribed authority under Section 151, made without independent application of mind, vitiates and renders the entire reassessment proceedings invalid. Such approvals, often indicated by brief, unreasoned endorsements, lead to the quashing of the reopening of assessment.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

Madhya Pradesh in CIT v. S. Goyanka Lime & Chemicals Ltd.
56 Taxmann.com 390 · 2015 · High Court
188
citing judgments

A sanction for issuing a notice under section 148 is invalid if the sanctioning authority grants approval mechanically, merely recording 'Yes, I am satisfied' without proper application of mind to the reasons for reassessment. The authority must demonstrate proper consideration to fulfill the statutory obligation under section 151.

CIT v. SPL’s Siddhartha Ltd.
345 ITR 223 · 2012 · High Court
164
citing judgments

Reassessment proceedings under Section 147 are invalid if the sanction required under Section 151 is obtained mechanically, without independent application of mind by the sanctioning authority, or is based on borrowed satisfaction.

Sabh Infrastructure Ltd. v. ACIT
398 ITR 198 · 2017 · High Court
137
citing judgments

Sanction under Section 151 granted in a mechanical manner, without application of mind, vitiates reassessment proceedings under Sections 147 and 148. The court also laid down guidelines for the Revenue to follow when reopening assessments, emphasizing the need to provide reasons and approval documentation to the assessee.

(P.) Ltd. v. ITO
221 ITR 538 · 1996 · Supreme Court
125
citing judgments

The sanction of a specified authority under Section 151 is a mandatory procedural check before issuing a notice under Section 148. This procedural safeguard aims to prevent mechanical reopening of assessments and harassment of the assessee.

Judgments citing sanction under section 151

Viswanadh Kandula, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

In the result, appeals of the assessee for the A

ITA 1085/HYD/2024[2018-19]Status: DisposedITAT Hyderabad07 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1084 To 1088 & 1027/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2014-15 To 2019-20) M/S Ace Tyres (P) Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/09/2025 घोषणा की तारीख/Pronouncement: 24/09/2025 आदेश/Order Per Vijay Pal Raothese Six Appeals By The Assessee Are Directed Against The Six Separate Orders Dated 29/05/2025, 30/05/2025, 04/06/2025, 096/06/2025, 17/06/2025 & 14/07/2025 Of The Learned Cit (A)-11, Hyderabad Arising From The Assessment Order Passed U/S 143(3) R.W.S. 147 Of The Act, Pursuant To The Search & Seizure Operations U/S 132 Of The Act, Dated 04/01/2023 In Case Of Exel Group Of Companies Including The Assessee For The A.Ys 2014-15 To 2019-20 Respectively. Since Common Issues Are Raised In These Group Of Six Appeals Arising From Same Facts & Search & Seizure Operation, Therefore, For The Sake Of Convenience, All Page 1 Of 78

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

148B has been accorded by Addl CIT/JCIT( Range head in a mechanical manner. 7. On the facts and circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section ... invalid and resultantly, impugned notice under Section 148 is bad in law. Modified Ground No.7 On the facts and circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2024[2017-18]Status: DisposedITAT Delhi02 Jan 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

income having "escaped assessment", without any fresh tangible material and without independent application of mind, is illegal and bad in law: (d) Sanction under section 151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred ... reassessment proceedings having been initiated on the basis of documents already available on record, are invalid and bad in law. Re (d): Sanction under section 151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner In the present case, in terms of sub-section

Cosmic Informatics Pvt. Ltd., New Delhi vs. ACIT Central Circle - 2, New Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2024[2013-14]Status: DisposedITAT Delhi02 Jan 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

income having "escaped assessment", without any fresh tangible material and without independent application of mind, is illegal and bad in law: (d) Sanction under section 151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner. The aforesaid contentions are elaborated hereunder: Re (a): Reassessment proceedings barred ... reassessment proceedings having been initiated on the basis of documents already available on record, are invalid and bad in law. Re (d): Sanction under section 151 of the Act for initiation of reassessment proceedings accorded in a mechanical manner In the present case, in terms of sub-section

Ashok Amratlal Shah, Mumbai vs. ITO Ward 42(1)(1), Mumbai

In the result, the appeals of the assessee bearing ITA Nos

ITA 4286/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Dec 2024AY 2015-16

Bench: Shri.B.R. Baskaran & Shri Anikesh Banerjee- A.Y. 2015-16 - A.Y. 2016-17 - A.Y. 2017-18

For Appellant: Ms. Kinjal BhutaFor Respondent: Shri Ram Krishn Kedia (SR DR)
Section 115BSection 132Section 139(1)Section 144BSection 147Section 148Section 148ASection 149Section 151Section 151A

appeal are rendered academic and do not require further deliberation. A.Ys 2016-17 & 2017-18 9.The assessee challenged the validity of the sanction under Section 151 of the Act for the issuance of notices under Section 148 for both assessment years. In these years, the Joint Commissioner of Income

Siyaram Exports India Pvt. Ltd., Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

ITA 440/JPR/2018[2013-14]Status: DisposedITAT Jaipur30 Dec 2024AY 2013-14
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

2 ITA No. 331/JPR/2017 & 435 to 440/JPR/2018 ITA No. 467,468 & 352/JPR/2018 & 145 & 151/JPR/2024 आयकर अपील सं./ITA No. 145

Shanti Chowdhry, Delhi vs. Income Tax Officer, Ward 69(2), Delhi

ITA 2975/DEL/2024[2012-13]Status: DisposedITAT Delhi29 Nov 2024AY 2012-13

Bench: Ms Madhumita Royassessment Year: 2012-13 Vs. Income Shanti Chowdhary, 305, Tax Officer, Plot Number 35, Jai Ward 69(2), Delhi Apartments, Sector-9, Rohini, Delhi-110085 Pan : Adcpc3729R (Appellant) (Respondent) Assessee By Shri Vipul Gupta, Advocate Department By Shri Sanjay Kumar, Sr, Dr

Section 133(6)Section 147Section 148Section 151

approval on the Form for recording the reasons for initiating proceedings under Section 147 of the Act and for obtaining the sanction under Section 151 of the Act. In that view of the matter the sanction is also not in terms of law and is liable to be quashed ... 2975/2024 at page-7 of the Paper Book filed before us, no date has been mentioned by the Learned PCIT while granting such sanction under Section 151 of the Act. The same, thus, cannot be said to be a valid one and therefore, consequentially the notice under Section

Gagan Arora, Delhi vs. Assessment Unit, Income-Tax Department

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 657/DEL/2024[2017-18]Status: DisposedITAT Delhi28 Nov 2024AY 2017-18

Bench: Shri Shamim Yahya & Shri Sudhir Pareeka.Yr. : 2017-18 Gagan Arora, Vs. Assessment Unit, Ad-34, First Floor, Income Tax Tagore Garden, Department, New Delhi – 110 027 Delhi (Pan: Afjpa5678Q) (Appellant) (Respondent)

For Appellant: Ms. Chinu Bhasin, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 143(2)Section 144Section 147Section 151Section 234ASection 271ASection 69A

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”, NEW DELHI BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER, AND SHRI SUDHIR

Deputy Commissioner of Income Tax, Nungambakkam Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

ITA 1437/CHNY/2024[2009-10]Status: DisposedITAT Chennai06 Nov 2024AY 2009-10

Bench: Shri Mahavir Singh, Hon'Ble & Shri S. R. Raghunatha, Hon'Bleआयकरअपीलसं./Ita No.: 1437/Chny/2024 & Co No.: 46/Chny/2024 निर्धारणवर्ष / Assessment Year: 2009-10 The Deputy Commissioner M/S. Cholamandalam Ms Of Income Tax, V. General Insurance Company Non-Corporate Circle -8, Limited, Room No. 507, 5Th Floor, No.2, Dare House, Chenai Annexe Building, G.P.O., Parrys, No. 121, M.G. Road, Chennai - 600 001. Chennai - 600 034. [Pan:Aabcc-6633-K] (अपीलार्थी/Appellant) (Respondent/Cross Objector) Assessee By : Ms. Kamakshi, Advocate For Mr. Sandeepbagmar, Advocate Department By : Mr.Nilaybaransom, Cit सुनवाई की तारीख/Date Of Hearing : 09.08.2024 घोषणा की तारीख/Date Of Pronouncement : 06.11.2024 आदेश / Order Per S. R. Raghunatha: This Appeal Filed By The Revenue & Cross Objection Filed By The Assessee Aredirected Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 07.03.2024 & Pertains To Assessment Year 2009-10. 2. The Revenue Has Raised The Following Grounds Of Appeal: 1. The Order Of The Learned Commissioner Of Income Tax (A) In

For Appellant: Ms. Kamakshi, Advocate forFor Respondent: Mr.NilayBaranSom, CIT
Section 143(2)Section 143(3)Section 148Section 40

आयकर अपीलीय अधिकरण, 'ए' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, CHENNAI श्री महावीर सिंह, उपाध्यक्ष एवं

Ashu Shukla, Gautam Budh Nagar vs. ITO Ward 5(1)(1), Gautam Budh Nagar

ITA 1853/DEL/2023[2009-10]Status: DisposedITAT Delhi29 Oct 2024AY 2009-10

Bench: Ms Madhumita Royassessment Year: 2009-10 Vs. Ito Ward 5(1)(1), Gautam Smt Ashu Shukla, Nri Residency, Flat No.204, Budh Nagar, Noida, Tower-1, Sector-45, Uttar Pradesh-201301 Noida, Gautam Buddha Nagar, Uttar Pradesh- 201 301 Pan :Bsips9841Q (Appellant) (Respondent) Assessee By Shri Pancham Sethi, Ca Department By Shri Sanjay Kumar, Sr, Dr

Section 142(1)Section 147Section 148Section 151(1)

connection judgments relied upon by the Learned AR have been duly considered by me. In all the judgments it has been held that sanction under Section 151 by the appropriate authority is a pre-requisite for issuance of re-opening notice under Section 148 of the Act ( when re-opening

Sonal Snehal Shah, Mumbai vs. ITO 19(3)(1), Mumbai

ITA 1653/MUM/2024[2012-13]Status: DisposedITAT Mumbai16 Oct 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

Section 10(38)Section 143Section 147Section 148Section 68

traded in the above script of Banas Finance Limited and earned long-term capital gain of Rs 272,18,541/- . vi. On sanction under section 151 of the act and relied on the decision of honourable Delhi High Court in case of the restaurant ACIT tea Ltd versus DCIT

Pankaj Dhandharia, Mumbai vs. ACIT-22(1), Mumbai

Appeal is dismissed

ITA 741/MUM/2024[2017-18]Status: DisposedITAT Mumbai15 Oct 2024AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shrisunil Kumar Singh, Jm

Section 142ASection 144BSection 147Section 148Section 250Section 50(2)(vi)Section 500Section 56(2)(vii)

more than three years have elapsed from the end of the relevant assessment year, whereas the learned AO had taken sanction under section 151) of the Act and hence for want of correct sanction, the entire assessment proceedings should be quashed, erred re-opening the assessment proceedings without appreciating that

Rising Stock Trade Private Limited, Jaipur vs. Income Tax Officer, Ward-1 (1), Jaipur

ITA 303/JPR/2022[2012-13]Status: DisposedITAT Jaipur01 Oct 2024AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajeev Sogani (C.A.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 147Section 148Section 151Section 153C

case and in law, the Id. AO has erred in issuing notice under Section 148 of Income Tax Act, 1961 without obtaining proper sanction under Section 151 of the Income Tax Act, 1961. The action of the Id. AO is illegal, unjustified, arbitrary and against the facts of the case ... case and in law, the Id. AO has erred in issuing notice under Section 148 of Income Tax Act, 1961 without obtaining proper sanction under Section 151 of the Income Tax Act, 1961. The action of 3 Rising Stock Trade Pvt. Ltd. vs. ITO the Id. AO is illegal, unjustified

Pnr Builders and Developers, Mumbai - Maharashtra vs. Income-Tax Officer Ward 20(2)(1), Mumbai, Piramal Chamber

ITA 3745/MUM/2024[AY2007-2008]Status: DisposedITAT Mumbai03 Sept 2024

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Paras SavlaFor Respondent: Shri Raj Singh Meel
Section 143Section 143(2)Section 143(3)Section 147Section 148Section 151Section 234ASection 69C

liable to be quashed. 3.5. Without prejudice, the Ld. CIT(A) failed to appreciate that there was no valid sanction under Section 151 before issuance of notice under section 148, and hence the notice under section 148 is bad in law. 4. Notice

Shree Maya Real Estate Pvt. Ltd., Nagpur vs. Deputy Commissioner of Income Tax, Central Circle-2(1), Nagpur

In the result, appeal filed by the assessee is allowed

ITA 228/NAG/2022[2019-20]Status: DisposedITAT Nagpur02 Sept 2024AY 2019-20

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Naresh JakhotiaFor Respondent: Shri Abhay Y. Marathe
Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 148(2)Section 151Section 43C

opened under section 147 of the Act after recording the reasons as required by section 148(2) of the Act and obtaining necessary sanction under section 151 of the Act. Accordingly, a notice under section 148 dated 12/02/2021, was issued and duly served upon the assessee through e-mail requiring

Shree Maya Real Estate Pvt. Ltd., Nagpur vs. Deputy Commissioner of Income Tax, Central Circle-2(1), Nagpur

In the result, appeal filed by the assessee is allowed

ITA 227/NAG/2022[2017-18]Status: DisposedITAT Nagpur02 Sept 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Naresh JakhotiaFor Respondent: Shri Abhay Y. Marathe
Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 148(2)Section 151Section 43C

opened under section 147 of the Act after recording the reasons as required by section 148(2) of the Act and obtaining necessary sanction under section 151 of the Act. Accordingly, a notice under section 148 dated 12/02/2021, was issued and duly served upon the assessee through e-mail requiring

Shakuntla Devi, Tijara vs. Income Tax Officer, Riico Industrial Area, Bhiwadi

In the result the appeal filed by the appellant stands allowed with no orders as to costs

ITA 864/JPR/2024[2014-15]Status: DisposedITAT Jaipur27 Aug 2024AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 148Section 2(14)Section 69B

notice issued under section 148 of the Income Tax Act after obtaining approval of the PCIT Alwar, as per the appellant the sanction under Section 151 (2) as these provisions stood than 5 SMT. SHAKUNTALA DEVI VS ITO, BHIWADI was required from JCIT therefore, the notice issued under section

Aadesh Commodities Pvt Ltd, Mumbai vs. National Faceless Assessment Centre, Delhi, Mumbai

In the result, the appeal by the assessee is allowed

ITA 3959/MUM/2023[2013-14]Status: DisposedITAT Mumbai19 Aug 2024AY 2013-14

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Jay BhansaliFor Respondent: Shri Harmesh Lal
Section 115BSection 143(2)Section 147Section 151Section 250Section 68

reopening the case off appellant without appreciating that the AO erred in not providing a copy of the necessary sanction under section 151 of the Act to reopen the case of the Appellant. The CIT(A)/AO failed to appreciate that assuming that the necessary sanction has been obtained

Mukeshgiri Hiragiri Goswami, Vadodara vs. Shri Harendra Kishore, Income Tax Officer, Vadodara

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 325/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad14 Jun 2024AY 2012-13

Bench: Ms. Suchitra Kambleassessment Year: 2012-13

Section 142(1)Section 144Section 147Section 148Section 151Section 69A

case was reopened under Section 147 of the Income Tax Act, 1961 after recording the reasons for doing so and obtaining necessary sanction under Section 151 of the Act, from the PCIT. Notice under Section 148 of the Act was issued on 29.03.2019 which was served upon the assessee

DCIT Circle-23(1), New Delhi vs. Ram Kumar Shokeen, New Delhi

In the result, the appeal of the Revenue is dismissed whereas the Cross Objection of the assessee is allowed

ITA 1009/DEL/2020[2011-12]Status: DisposedITAT Delhi13 Jun 2024AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Kumar

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Vivek Vardhan, Sr.DR
Section 143(3)Section 147Section 148Section 148(1)Section 148(2)Section 151

151 are administrative in nature and there is no requirement in law that competent authority needs to record its own reasons for sanction under Section 151 of the Act. Once, the approval is granted, the statutory presumption is to be drawn that the competent authority has acted with due application ... held in Chhugamal Rajpal Vs. S.P. Chaliha (1971) 79 ITR 603 (SC). 8. The requirement of sanction under Section 151 is salutary as it ensures that reopening notices are not lightly issued and to shun any misconception or misunderstanding on the part of the AO resulting in harassment

Deputy Commissioner of Income Tax, Central Circle-19, New Delhi., Delhi vs. Sandeep Bajaj, Delhi

In the result, the Cross Objection filed by the assessee is

ITA 2993/DEL/2023[2014-15]Status: DisposedITAT Delhi29 May 2024AY 2014-15

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 147Section 148Section 151Section 2(22)(e)Section 56

after four years seeking to reopen aforesaid assessment Commissioner simply affixed 'approved' at bottom of report prepared by Assessing Officer and accorded sanction under section 151(1) for reopening assessment Nowhere Commissioner had recorded a satisfaction note Whether Commissioner had accorded sanction under section 151(1) after applving his mind