Income Tax Act, 1961 – Sections 143(3), 147, 148 and 151 – Reopening of assessment – Validity – Revenue filed appeal against order passed by CIT(A) arising from reassessment order passed by AO under Section 143(3) read with Section 147 of the Act pertaining to AY 2011-12 – Assessee has also filed cross objection in this appeal challenging assumption of jurisdiction under Section 147 of the Act – Since said challenge strikes to root of litigation, cross objection is taken up for adjudication at first instance – Whether CIT(A) has erred in confirming reopening of assessment under Section 147 of the Act – HELD – Section 151 of the Act provided that powers under Section 147 of the Act are not exercised by AO unless designated superior officer is satisfied that condition precedent for exercise of powers as provided under Section 147 of the Act is fulfilled – To meet this avowed objective enshrined in enactment of Section 151 of the Act, it is incumbent upon superior authority to apply its mind to basis derived by AO for alleged escapement while granting sanction to proposal for reopening – On basis of satisfaction and approval of PCIT, re-assessment was initiated and completed – As pointed out on behalf of assessee, PCIT has simply recorded ‘action under Section 148 of the Act approved’ towards sanction of reassessment proceedings – Approval granted by PCIT under Section 151 of the Act suffers from vice of non application of mind – Re-assessment proceedings initiated under Section 147 of the Act as a consequence of such invalid approval is without sanction of law and consequently, re-assessment order in question is bad in law and hence, set aside – Cross Objection allowed