The Assessing Officer reopened the assessment solely on the basis of the Investigation Wing report and undisclosed handwritten papers without making any independent enquiry. The sanctioning authority also granted approval under section 151 on incorrect facts, assuming that the assessment was being framed for the first time although an assessment under section 143(3) had already been completed. The Tribunal held that both the reasons recorded and the approval reflected complete non-application of mind. The reassessment was therefore quashed. (AY. 2008-09).