ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -4(3), MUMBAI, MUMBAI vs. VINOD JHAMAMAL LULLA, MUMBAI

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ITA 6495/MUM/2026Status: DisposedITAT Mumbai18 September 2026AY 2015-1610 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the notice under section 148 was issued without jurisdiction as the mandatory approval under section 151(2) from the Joint Commissioner was not obtained. The extension of time under TOLA did not alter the requirement for the specific authority's satisfaction.

What were the facts?

The Assessing Officer issued a notice under section 148 on 31.03.2021 for AY 2015-16, obtaining approval from the Principal Commissioner. The assessee contended that due to the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, the approval should have been from the Joint Commissioner under section 151(2).

What were the issues?

Whether the reassessment notice issued under section 148 was valid when approval was obtained from the Principal Commissioner instead of the Joint Commissioner, considering the impact of TOLA.

Which sections of the Income-tax Act were involved?

Section 148,Section 151,Section 69,Section 69A

AI-generated summary — verify with the full judgment below

Before: SHRI AMIT SHUKLA & SHRI ARUN KHODPIA

For Appellant: Shri Dharan V. Gandhi
For Respondent: Shri Ravi Teja (Sr. DR)
Hearing: 18.09.2026Pronounced: 18.09.2026

आदेश की प्रतितलतप अग्रेतिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आय क्त / CIT

P a g e | 10 ITA No. 6495/Mum/2026 CO 261/M/2026 A.Y. 2015-16 Vinod Jhamamlal Lulla दिभागीय प्रदिदनदि, आयकर अपीलीय अदिकरण DR, ITAT, 4. Mumbai 5. गार्ड फाईल / Guard file. सत्यादपि प्रदि //True Copy// आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अतिकरण/ ITAT, Bench, Mumbai.

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