CIT’s Sanction u/s 148/151 of the Income Tax Act if mechanical and without reasons is invalid

Rubber stamping of underlying material is hardly a process which can get the imprimatur of the Court as it suggests that the decision has been taken in a mechanical manner. Even if the reasoning set out by the ITO was to be agreed upon, the least, which is expected, is that an appropriate endorsement is made in this behalf setting out brief reasons. If a material is not in existence or if a material is such of which the assessee had no knowledge there would be no duty to disclose such material.
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