Central India Electric Supply Co. Ltd. v. ITO
What is Central India Electric Supply Co. Ltd. v. ITO authority for?
Reassessment proceedings under Section 147/148 are invalid if initiated solely due to a change of opinion or reappraisal of facts already available during the original assessment. The approval required under Section 151 for reassessment must reflect the independent application of mind by the approving authority, not a mere mechanical endorsement.
judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.
Also referred to as
Central India Electric Supply Co. Ltd. v. ITO · reassessment change of opinion · Section 147 reopening · Section 148 notice · mechanical approval Section 151 · reappraisal of facts · no new information · AO's independent satisfaction · jurisdiction invalid · 339 ITR 169 · 51 DTR 51 · validity of reassessment
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Judgments citing Central India Electric Supply Co. Ltd. v. ITO
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