Allowing the petition the Court held that the competent authority must apply its mind independently on the basis of material placed before it before grant of approval or sanction. It was evident that the approval for notice of reassessment dated March 28, 2021 was a general order of approval for all the 111 cases. There was no whisper as to what material had weighed in the grant of approval in the present case. While the Principal Commissioner was not required to record elaborate reasons, he had to record satisfaction after application of mind. The approval is a safeguard and has to be meaningful and not merely ritualistic or formal. The sanction order did not refer to the material of any of the 111 cases. The grant of approval in such a manner did not fulfil the requirement of section 151 of the Act.  The notice issued under section 148 of the Act for the assessment year 2015-2016 and the proceedings emanating therefrom were not valid.(AY. 2015-16)