Pvt Ltd. v. ACIT

93 Taxmann.com 296High Court2018#1160 most cited

What is Pvt Ltd. v. ACIT authority for?

Approval granted by the Principal Chief Commissioner or Principal Commissioner under Section 151 for reassessment proceedings under Section 148 must reflect due application of mind. A mere endorsement of "approved" without reasons or reference to material is insufficient, as the approval serves as a safeguard and must be meaningful, not ritualistic or formal.

98

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2022 to 2026.

Also referred to as

SBC Minerals Pvt Ltd v ACIT · Section 151 approval · Section 148 reassessment notice · mechanical approval · application of mind · PCCIT satisfaction · Chief Commissioner approval · reassessment sanction · reasons for approval · income escaping assessment

Issues it is cited on

Judgments citing Pvt Ltd. v. ACIT