Chanchal Kumar Chatterjee v. Income Tax Officer

93 ITR 130High Court1974#2098 most cited

What is Chanchal Kumar Chatterjee v. Income Tax Officer authority for?

The sanctioning authority must apply its mind to the reasons recorded by the Assessing Officer before granting approval for reassessment or other proceedings, and cannot grant such approval in a mechanical manner by merely rubber-stamping "Yes".

55

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2011 to 2026.

Also referred to as

Chanchal Kumar Chatterjee · 93 ITR 130 · Section 151 · Section 148 · mechanical approval · rubber stamping · application of mind · sanctioning authority · approval for reassessment · reasons recorded · reassessment validity

Sections most often in play

Section 148Section 151Section 143(3)Section 147Section 153ASection 153DSection 132Section 133A

Issues it is cited on

section 271aab(1a)section 151(2)section 144basection 158bgsection 142(2a)approval under section 151section 271aabsection 148(2)section 151(1)section 271aac(1)section 153bsanctioning authority

Judgments citing Chanchal Kumar Chatterjee v. Income Tax Officer

Govind Sharma, Mathura vs. ITO, Ward 1(3)(1), Mathura

In the result, the assessee’s appeal is allowed

ITA 428/AGR/2025[2015-16]Status: DisposedITAT Agra17 Apr 2026AY 2015-16
Section 10(38)Section 147Section 148Section 151Section 250Section 68

…"Yes" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under: - "19. In respect of the first plea, if the judgments in Chhugamal Rajpal [1971] 71 ITR 603(SC), Chanchal Kumar Chatterjee [1974] 93 ITR 130 (Cal) and Govinda Choudhary and Sons case [1977] 109 ITR 370 (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to approval by…

Vipul Agrawal, Ghaziabad, Uttar Pradesh vs. ACIT, Ghaziabad, Uttar Pradesh

In the result, the appeal of the assessee is allowed

ITA 5066/DEL/2024[2012-13]Status: DisposedITAT Delhi27 Mar 2026AY 2012-13

Bench: Shri M. Balaganesh & Shri Sudhir Kumarvipul Agrawal, Vs. Acit, 35, Chandrapuri, Hapur Chungi, Up Hapur, Road, Up (Appellant) (Respondent) Pan: Abqpa6874P

For Appellant: Shri Manoj Kumar, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 133(6)Section 143(3)Section 147Section 148Section 148ASection 151

…Yes" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under: - "19. In respect of the first plea, if the judgments in Chhugamal Rajpal [1971] 79 ITR 603 (SC), Chanchal Kumar Chatterjee [1974] 93 ITR 130 (Cal) and Govinda Choudhary and Sons case [1977] 109 ITR 370 (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to approval by…

Bhavika Bhuwalka, Delhi vs. Income Tax Officer, Ward-5(1)(2), Noida

In the result, the appeal of the assessee is allowed

ITA 8258/DEL/2025[2013-14]Status: DisposedITAT Delhi30 Jan 2026AY 2013-14

Bench: Shri C.N. Prasad[Assessment Year: 2013-14] Bhavika Bhuwalka Vs. Ito C055, Iind Floor, Preet Ward-5 (1) (2) Vihar, Delhi Noida Pan No. Amnpb8209R Appellant Respondent

Section 147Section 148Section 151Section 250Section 69

…Yes" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under: - "19. In respect of the first plea, if the judgments in Chhugamal Rajpal [1971] 79 ITR 603 (SC), Chanchal Kumar Chatterjee [1974] 93 ITR 130 (Calcutta) and Govinda Choudhury and Sons case [1977] 109 ITR 370 (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to approv…

Vikas Chandra HUF, Aligarh vs. ITO Ward-4(1)(1), Aligarh

In the result, the appeal of the assessee is allowed

ITA 450/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Pankaj Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 139(1)Section 147Section 148Section 148ASection 151

…Yes" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under: - "19. In respect of the first plea, if the judgments in Chhugamal Rajpal [1971] 79 ITR 603 (SC), Chanchal Kumar Chatterjee [1974] 93 ITR 130 (Cal) and Govinda Choudhary and Sons case [1977] 109 ITR 370 (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to approval by…

Essen Marketing Pvt. Ltd., Kolkata vs. I.T.O., Ward - 9(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2241/KOL/2025[2012-2013]Status: DisposedITAT Kolkata18 Dec 2025AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 9(1) Essen Marketing Pvt. Ltd. Aaykar Bhawan, P-7, 101/1/2/1, B.T. Road, Bonhoogly, Chowringhee Square, Kolkata- Vs. Kolkata-700090, West Bengal 700069, West Bengal (Appellant) (Respondent) Pan No. Aaace5871A Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Ruchika Sharma, Dr Date Of Hearing: 03.12.2025 Date Of Pronouncement: 18.12.2025 O R D E R Per Rajesh Kumar, Am: This Is An Appeal Preferred By The Assessee Against The Order Of The National Faceless Appeal Centre, Delhi (Hereinafter Referred To As The “Ld. Cit(A)”] Dated 29.07.2025 For The Ay 2012-13. 2. At The Time Of Hearing, The Counsel Of The Assessee Pressed Ground No.4, Which Is In Respect Of Reopening Of Assessment Not Being In Accordance With Law & Therefore, The Entire Reassessment Is Liable To Be Quashed.

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ruchika Sharma, DR
Section 147Section 148Section 151Section 151(1)

…Yes" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under: - "19. In respect of the first plea, if the judgments in Chhugamal Rajpal (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case (1977) 109 ITR 370 (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to approval by…

1.Income Tax Officer Ward 3(1), Kolkata vs. Anushreya Investment Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2543/KOL/2024[2011-12]Status: DisposedITAT Kolkata19 Nov 2025AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Income Tax Officer, Ward 3(1), Anushreya Investment Private Kolkata Limited P-7, Chowringhee Square, 5Th Floor, Mangalam-A, 24 4Th Floor, Aaykar Bhawan Hemanta Basu Sarani, Vs. Poorva, Kolkata-700069, Kolkata-700001, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aacca3658B Assessee By : Shri N.S. Saini, Ar Revenue By : Shri Susanta Saha, Dr Date Of Hearing: 31.10.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri N.S. Saini, ARFor Respondent: Shri Susanta Saha, DR
Section 143(2)Section 143(3)Section 147Section 148Section 151Section 151(2)Section 68

…Yes" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under: - "19. In respect of the first plea, if the judgments in Chhugamal Rajpal (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case (1977) 109 ITR 370 (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to approval by…

Pr Commissioner of Income Tax Central 2 vs. M/S. Believe Constructions P. Ltd

ITA/555/2025HC Delhi29 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153DSection 260A

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to app…

Principal Commissioner of Income Tax-7 vs. M/S Shivganesh Builders Pvt. Ltd

ITA/550/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to app…

Principal Commissioner of Income Tax-7 vs. M/S Shine Star Buildcon Pvt. Ltd

ITA/549/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to app…

Pr. Commissioner of Income Tax-1 vs. M/S. Believe Constructions P. Ltd

ITA/542/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to app…

Pr. Commissioner of Income Tax, I vs. M/S. Bhudeva Estates P. Ltd

ITA/539/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to app…

Prrincipal Commissioner of Income Tax-7 vs. M/S Shine Star Buildcon Pvt. Ltd

ITA/540/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to app…

Pr. Commissioner of Income Tax-4 vs. Sh. Gobind Kumar Goyal

ITA/544/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to app…

Principal Commissioner of Income Tax-7 vs. M/S Shivgori Builders Pvt

ITA/536/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to app…

ACIT, CC- 15, New Delhi vs. Saloni Narang, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1496/DEL/2018[2012-13]Status: DisposedITAT Delhi27 Oct 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2012-13] Asst. Commissioner Of Income Saloni Narang, Tax, Central Circle-15, 5, Dr. G.G. Narang Marg, Room No.353, E-2, Ara Vs Cavalary Lane, Centre, Jhandewalan Ext. Delhi-110007 New Delhi-110055 Pan-Aafpn2692C Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv. & Shri Somil Agarwal, Adv. Revenue By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 27.10.2025

Section 132Section 143(3)Section 153Section 153ASection 153DSection 69A

…s" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— "19. In respect of the first plea, if the judgments in Chhugamal Rajpal, [1971] 79 ITR 603 (SC) , Chanchal Kumar Chatterjee, [1974] 93 ITR 130 (Calcutta) and Govinda Choudhury and Sons case, [1977] 109 ITR 370 (Orissa) (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting…

Pr. Commissioner of Income Tax-1 vs. Ashutosh Developers P. Ltd

Appeals are dismissed, as no substantial question of law arises

ITA/522/2025HC Delhi15 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153D

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to appro…

Principal Commissioner of Income Tax-7 vs. M/S Shivgori Builders Pvt. Ltd

Appeals are dismissed, as no substantial question of law arises

ITA/523/2025HC Delhi15 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153D

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to appro…

Principal Commissioner of Income Tax-1 vs. M/S Mdlr Resorts Pvt. Ltd

Appeals are dismissed, as no substantial question of law arises

ITA/530/2025HC Delhi15 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153D

…ould suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under:— “19. In respect of the first plea, if the judgments in Chhugamal Rajpal, (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee, (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case, (1977) 109 ITR 370(Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to appro…

M/S. Sunglow Vinimay Private Limited, Kolkata vs. ITO, Ward 6(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 263/KOL/2025[2015-16]Status: DisposedITAT Kolkata08 Oct 2025AY 2015-16

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 144BSection 147Section 148Section 148A

…Yes" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under: - "19. In respect of the first plea, if the judgments in Chhugamal Rajpal (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case (1977) 109 ITR 370 (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to approval by…

M/S. Sunglow Vinimay Private Limited, Kolkata vs. ITO, Ward 6(1), Kolkata

In the result, the appeal of the assessee is

ITA 262/KOL/2025[2014-15]Status: DisposedITAT Kolkata08 Oct 2025AY 2014-15

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 144BSection 147Section 148Section 148A

…"Yes" would suggest that the decision was taken in a mechanical manner. Paragraph 19 of the said decision is reproduced as under: "19. In respect of the first plea, if the judgments in Chhugamal Rajpal (1971) 79 ITR 603 (SC), Chanchal Kumar Chatterjee (1974) 93 ITR 130 (Cal) and Govinda Choudhury and Sons case (1977) 109 ITR 370 (Orissa) are examined, the absence of reasons by the Assessing Officer does not exist. This is so as along with the proforma, reasons set out by the Assessing Officer were, in fact, given. However, in the instant case, the manner in which the proforma was stamped amounting to approval by…

Chanchal Kumar Chatterjee v. Income Tax Officer (93 ITR 130) — Cited in 55 Judgments | BharatTax