SANGEETA SUNIL JOLAPURE,SARVOLIM, SALCETE, GOA vs. INCOME TAX OFFICER WARD -1, OFFICE OF THE ITO, MARGAO, GOA

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ITA 321/PAN/2025Status: DisposedITAT Panaji12 August 2026AY 2014-158 pages

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

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the approval granted under Section 151(2) was mechanical and not in accordance with the law, as it was a consolidated approval for multiple assessees without specific satisfaction recorded for each case. Consequently, the reassessment proceedings were quashed.

What were the facts?

The assessee's assessment for AY 2014-15 was reopened under Section 147. The assessee challenged the validity of the reassessment proceedings, primarily on the ground that the approval obtained under Section 151(2) was mechanical and lacked proper application of mind.

What were the issues?

Whether the reassessment proceedings initiated under Section 147 were valid when the approval under Section 151(2) was mechanical and lacked proper application of mind.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 148,Section 151,Section 69

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PANAJI BENCH, ‘SMC’ PANAJI

Before: DR.MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri P.K. Bansal
For Respondent: Shri Mayur Kamble
Hearing: 11.08.2026Pronounced: 12.08.2026

आदेश की प्रतिलिपि अग्रेपिि / Copy of the Order forwarded to : अपील र्थी / The Appellant. 1. प्रत्यर्थी / The Respondent. 2. 3. The Pr. CIT concerned. विभ गीय प्रतितनधि, आयकर अपीलीय अधिकरण, Panaji 4. ‘SMC’ Bench / DR, ITAT, Panaji ‘SMC’ Bench ग र्ड फ़ इल / Guard File. 5.

आिेश नुस र / BY ORDER,

// True Copy // Assistant Registrar, आयकर अपीलीय अधिकरण, Panaji/ ITAT, Panaji

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