Dual Jurisdiction Defects

The ITAT held that approval under Section 151 must reflect independent application of mind and cannot be a mere ritualistic endorsement. 

A mechanical “approval” vitiates jurisdiction. Additionally, reassessment initiated by an officer lacking jurisdiction, contrary to CBDT instructions, renders proceedings void ab initio. The Tribunal quashed the reassessment without examining merits, reinforcing procedural safeguards as substantive rights.