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
Also reported as
475 ITR 360