Mistake in Recorded reason- No reason to believe – Approval u/s 151 is mechanical.

A mistake in recorded reason could certainly not be the reason to believe that petitioner’s income has escaped assessment. Approval under Section 151 of the Act also has been given on the same reasons, which would also indicate total non application of mind by not only the JAO but also by the Revenue Head who had recommended the case to the Principal CIT and also Principal CIT himself. One thing is evident that the approval is granted in a mechanical way without applying their mind.