How many judgments cite Union of India v. Rajeev Bansal?

713 judgments on BharatTax cite Union of India v. Rajeev Bansal (469 ITR 46), spanning 2023 to 2026.

Which sections of the Income Tax Act does Union of India v. Rajeev Bansal come up under?

It is most often cited in judgments turning on Section 148, Section 147, Section 148A, Section 151, Section 149, Section 144B.

Union of India v. Rajeev Bansal

469 ITR 46Supreme Court of India2024#72 most cited

What is Union of India v. Rajeev Bansal authority for?

The legal fiction created by the Ashish Agarwal judgment stops the limitation clock for Section 148 notices from the date of the deemed notice. Orders issued without proper jurisdiction, or those inconsistent with statutory prescriptions, are a nullity, and there can be no waiver of such fundamental jurisdictional requirements.

713

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2023 to 2026.

Also referred to as

Union of India v. Rajeev Bansal · Section 148 notice limitation · Ashish Agarwal legal fiction · TOLA applicability · reassessment jurisdiction · time-barred notice · order without jurisdiction · Section 149 · Section 148A

Also reported as

167 Taxmann.com 70301 Taxmann 238

Sections most often in play

Section 148 Section 147 Section 148A Section 151 Section 149 Section 144B Section 250 Section 144

Read the full judgment

Issues it is cited on

section 149a(c)section 149a(d)section 149a section 151(i)section 149(1)(a)section 3(1)section 148a(a)section 148 notice section 151(ii)section 149(1)section 149(1)(b)order under section 148a(d)

Judgments citing Union of India v. Rajeev Bansal

The Ookal Farmers Service Cooperative Society Limited, Warangal vs. ITO., Ward-1, Warangal

In the result, all three appeals of the assesssee, i

ITA 1144/HYD/2025[2016-17]Status: DisposedITAT Hyderabad24 Dec 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 80PSection 80P(2)(d)

…am v. Savitribai Sopan Gujar and CCE v. Flock (India) (P) Ltd.)" (emphasis supplied by us) 20. We further find that the Hon'ble Supreme Court in its recent order passed in the case of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) had, inter alia, observed that the order passed without jurisdiction is nullity. It was further observed that if a statute expressly confers a power or imposes a duty on a particular authority, then such power or duty must be exercised or performed by that authority itself. The Hon'ble Apex Court had further observed that any exercise of powe…

The Ookal Farmers Service Cooperative Society Limited, Warangal vs. ITO., Ward-1, Warangal

In the result, all three appeals of the assesssee, i

ITA 1143/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Dec 2025AY 2015-16

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 80PSection 80P(2)(d)

Naresh Amratlal Shah, Mumbai vs. ITO Ward-27(2)(1), Mumbai

In the result, the appeal of the In the result, the appeal of the Assessee is allowed allowed

ITA 6142/MUM/2025[2020-21]Status: DisposedITAT Mumbai24 Dec 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Respondent: Assessee by Shri Jitendra Singh & Shri

Section 115BSection 148Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) ITA No. 6142/MUM/25 Assessment Year: 2020-21 Naresh Amratlal Shah, ITO Ward – 27(2)(1), 204/205 Kalindi, Neelkanth Valley, Room No. 413, 4th Floor, Tower No.6, Vs. Vashi Station Complex, Vashi – 400703. 7th Road, Rajawadi, Ghatkopar – (East), Mumbai – 400077. PAN – AAVPS2055E Appellant Respondent : Assessee by Shri Jitendra Singh & Shri Akshay Pawar : Revenue by Shri Leyaqat Ali Aafaqui, Sr. D.R. : Date of Hearing 27/11/2025 : Date of pronouncement 24/12/2025…

Veera Lakshmi Bokka, Delhi vs. ITO Ward 67(1), Delhi

Appeal of the assessee are allowed

ITA 8012/DEL/2025[2015-20216]Status: DisposedITAT Delhi24 Dec 2025

Bench: Sh. Satbeer Singh Godaraita No. 8012/Del/2025 : Asstt. Year: 2015-16 Veera Lakshmi Bokka, Vs Income Tax Officer, 49, C-Block Complex, Minto Road, Ward-67(1), New Delhi-110002 New Delhi-110002 (Appellant) (Respondent) Pan No. Alepb2589C Assessee By: Sh. Gaurang Khakhkhar, Ca Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 24.12.2025 Date Of Pronouncement: 24.12.2025 Order This Assessee’S Appeal For Assessment Year 2015-16 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081061500(1) Dated 23.09.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Gaurang Khakhkhar, CAFor Respondent: Sh. Amit Shukla, Sr. DR

Section 147Section 148

…lf set into motion by the learned Assessing Officer vide section 148 notice issued on 31.03.2022. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs. Rajiv Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation 2 Veera Lakshmi Bokka and Other Laws [Relaxation and Amendment of Certain Provisions] Act, 2020 “TOLA” would not apply for assessment year 2015-16 herein. It further emerges that the very issue between the parties is no more res integra in light of the tribunal’s recent learned coordinate bench’s order dated 23…

Lalbiakdiki Hauzel, Aizawl vs. ITO W-50(1), Delhi

Appeal of the assessee are allowed

ITA 7984/DEL/2025[2015-16]Status: DisposedITAT Delhi24 Dec 2025AY 2015-16

Bench: Sh. Satbeer Singh Godaraita No. 7984/Del/2025 : Asstt. Year: 2015-16 Lalbiakdiki Hauzel, Vs Income Tax Officer, 198 A-1/160, Chaltlang B.O. Aizawl Ward-50(1), Aizawl, Mizoram-796012 New Delhi (Appellant) (Respondent) Pan No. Aeaph5467E Assessee By: None Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 24.12.2025 Date Of Pronouncement: 24.12.2025 Order This Assessee’S Appeal For Assessment Year 2015-16 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1080279689(1) Dated 02.09.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Amit Shukla, Sr. DR

Section 147Section 148

…the learned Assessing Officer vide section 148 notice issued on 31.03.2022. This is for the precise reason that the department already appears to have conceded the very issue of limitation aspect in Union of India Vs Rajiv 2 Lalbiakdiki Hauzel Bansal (2024) 469 ITR 46 (SC) that the provision of Taxation and Other Laws [Relaxation and Amendment of Certain Provisions] Act, 2020 “TOLA” would not apply for assessment year 2015-16 herein. It further emerges that the very issue between the parties is no more res integra in light of the tribunal’s recent learned coordinate bench’s order dated 23.07.2025 passed in ITA…

Arun Gupta, Delhi vs. Dcot Circle 49(1), Delhi

In the result, appeal of the Assessee is allowed

ITA 4702/DEL/2025[2015-16]Status: HeardITAT Delhi24 Dec 2025AY 2015-16

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalarun Gupta Vs Dcit C/O C. S. Anand, Adv B-81, First Circle-49(1) Floor (Part-B), Defence Colony, Civic Centre, Bhishmapitamah Marg, New Minto Road, Delhi Delhi-24 Pan: Aehpg9780Q Appellant Respondent Assessee By Sh. C. S. Anand, Adv Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 23/12/2025 Date Of Pronouncement 24/12/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal

Section 144BSection 147Section 148Section 148A

…that the notice issued u/s 148 of the Act dated 27/07/2022 was barred by limitation and the last date of issuing notice u/s 148 of the Act was 27/07/2022, thus relying on the Judgment of Hon'ble Supreme Court in the case of Union of India vs. Rajiv Bansal (469 ITR 46), sought for allowing the Appeal. 4. Per contra, the Ld. Department's Representative vehemently submitted that the Assessee has not appeared before the A.O. as well as the Ld. CIT(A) and the above ground urged by the Assessee was not raised before any of the authority, therefore, sought for remanding the issue involved in the present Appeal to…

Muse Farms Pvt Ltd, Delhi vs. Assessment Unit Income Tax Department, Delhi

Appeal of the assessee are allowed

ITA 4082/DEL/2025[2015-16]Status: DisposedITAT Delhi24 Dec 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2015-16 M/S. Muse Farms Pvt. Ltd., Vs. Assessment Unit (Itd), B-2/201 Basement, Delhi Safdarjung Enclave, New Delhi Pan: Aahcm1513E (Appellant) (Respondent) Assessee By Sh. Sanjeev Khurana, Ca Department By Sh. Manish Gupta, Sr. Dr Date Of Hearing 24.12.2025 Date Of Pronouncement 24.12.2025 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2015-16, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1076003088(1), Dated 02.05.2025 Involving Proceedings Under Section 147 R.W.S. 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case Files Perused. 2. We Notice During The Course Of Hearing That There Arises The First & Foremost Issue Of Validity Of The Impugned Reopening Itself Set Into Motion By The Learned Assessing Officer Vide Section 148 Notice Issued On 27.07.2022. This Is For The Precise Reason That The Department Already Appears To Have Conceded The Very Issue Of Limitation Aspect In Union Of India Vs Rajiv Bansal (2024) 469 Itr 46 (Sc) That The Provision Of Taxation & Other Laws [Relaxation & Amendment Of Certain Provisions] Act, 2020 “Tola” Would Not Apply For Assessment Year 2013-14 Herein. It Further Emerges That The Very Issue Between The Parties Is No More Res Integra In Light Of The Tribunal’S Recent Learned Coordinate Bench’S Order Dated 23.07.2025 Passed In Ita No. 2307/Del/2025 (Sh. Deepak Agarwal Vs. Dcit) Having Quashed A Similar Reopening Therein, Reading As Under:

Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2015-16 M/s. Muse Farms Pvt. Ltd., Vs. Assessment Unit (ITD), B-2/201 Basement, Delhi Safdarjung Enclave, New Delhi PAN: AAHCM1513E (Appellant) (Respondent) Assessee by Sh. Sanjeev Khurana, CA Department by Sh. Manish Gupta, Sr. DR Date of hearing 24.12.2025 Date of pronouncement 24.12.2025 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2015-16, arises against the Commissioner of Income Tax (Appeals)/National F…

Kanchan Devi Agarwal, Surat vs. ITO, Ward 1(2)(1), Surat

The appeal of the assessee is allowed

ITA 480/SRT/2025[2017-18]Status: DisposedITAT Surat23 Dec 2025AY 2017-18

Bench: S/Shri Sanjay Garg & Bijayananda Pruseth

For Appellant: Shri Ramesh Malpani, CAFor Respondent: Shri Ajay Uke, Sr.DR

Section 133(6)Section 147Section 148Section 148ASection 151Section 234BSection 68

…os.479 & 480/SRT/2025 Page 6 of 11 and information relied upon by the Revenue within thirty days from the date of the judgment. The effect of this direction was summarized by the Apex Court in the case of Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) as under: 106. …..To summarize, the combined effect of the legal fiction and the directions issued by this Court in Ashish Agarwal (supra) is that the show cause notices that were deemed to have been issued during the period between 1 April 2021 and 30 June 2021 were stayed till the date of supply of the relevant information and material by…

Kanchan Devi Agarwal, Surat vs. ITO, Ward 1(2)(1), Surat

The appeal of the assessee is allowed

ITA 479/SRT/2025[2016-17]Status: DisposedITAT Surat23 Dec 2025AY 2016-17

Bench: S/Shri Sanjay Garg & Bijayananda Pruseth

For Appellant: Shri Ramesh Malpani, CAFor Respondent: Shri Ajay Uke, Sr.DR

Section 133(6)Section 147Section 148Section 148ASection 151Section 234BSection 68

Roy Banerjee Development Pvt. Ltd., Kolkata vs. I.T.O., Ward - 1(1), Kolkata

The appeal of the assessee is allowed

ITA 1584/KOL/2025[2015-2016]Status: DisposedITAT Kolkata23 Dec 2025AY 2015-2016

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 147Section 148Section 148ASection 250

…e Ld. CIT(A)]. 2. The only issue raised by the Counsel of the assessee is in respect of A.Y. 2015-16, being time barred by limitation in consonance with the de- cision of the Hon'ble Apex Court in the case of Union of India and other Vs. Rajeev Bansal [2024] 469 ITR 46 (SC), dated 03.10.2024. 3. The facts in brief are that the assessee filed the return of income on 08.01.2016, declaring total loss at ₹89,590/-. The case of the assessee 2 Roy Banerjee Development Pvt. Ltd. was reopened u/s 147 of the Act after the ld. AO received information that assessee received accommodation entry amounting to ₹52,50,672/-. T…

Gamnaram Okhaji Prajapati, Mumbai vs. DCIT. Circle 1(2)(1), Mumbai

Appeal is allowed

ITA 6791/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Dec 2025AY 2016-17

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh ShahFor Respondent: Shri Swapnil Choudhary

Section 115BSection 144Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 153CSection 234A

…8A(d) of the Act and issuance of notice under Section 148 of the Act (new regime) for the Assessment Year 2016-2017. 7. In this regard we deem it appropriate to refer to judgment of the Hon’ble Supreme Court in the case Union of India vs. Rajeev Bansal [2024] 469 ITR 46 (SC)[03/10/2024]. The Hon’ble Supreme Court had, while dealing with the issue of approval from specified authority in terms of Section 151 of the Act, made the following observations: “74. The above table indicates that the specified authority is directly co-related to the time when the notice is issued. This plays out as follows under the old re…

Gamnaram Okhaji Prajapati, Mumbai vs. Dy. CIT Circle 1(2)(1), Mumbai

Appeal is allowed

ITA 6790/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-16

For Appellant: Shri Dinesh ShahFor Respondent: Shri Swapnil Choudhary

Section 115BSection 144Section 144BSection 147Section 148Section 148ASection 153CSection 234Section 234BSection 69A

…on 24/05/2023. Since the said notice has been issued after 01/04/2021, the same is without jurisdiction and has to be withdrawn in light of the concession made by the Revenue before the Hon'ble Supreme Court in case of Union of India Vs. Rajeev Bansal [2024] 469 ITR 46 (SC). In support the Learned Authorised Representative for the Assessee placed on record the recent judgment of the Hon'ble Bombay High Court in the case of Cherian Nallathu Abraham Annamma VS. Income-tax Officer, International Tax, Ward-1(1)(1), Mumbai [2025] 179 taxmann.com 433 (Bombay)/[2025] 307 Taxman 367 (Bombay)[13-10-2025] and judgment in…

Shantilal Narottamdas Panchal, Malad East vs. ITO-41(3)(4), Mumbai, Bandra Kurla Complex

Appeal is allowed

ITA 3570/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18

Bench: Him.

For Appellant: Shri Ravindra PoojaryFor Respondent: Shri Bhagirath Ramawat

Section 144BSection 147Section 148Section 148ASection 151Section 56(2)(vii)

…sment Year 2017-2018 issuance of notice under Section 148 of the Act (new regime) for the Assessment Year 2017-2018. 7. In this regard we deem it appropriate to refer to judgment of the Hon’ble Supreme Court in the case Union of India vs. Rajeev Bansal [2024] 469 ITR 46 (SC)[03/10/2024]. The Hon’ble Supreme Court had, while dealing with the issue of approval from specified authority in terms of Section 151 of the Act, made the following observations: “74. The above table indicates that the specified authority is directly co-related to the time when the notice is issued. This plays out as follows under the old re…

Jakson Limited, Delhi vs. DCIT, CC-4, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 5014/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR

Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

…ITA No. 5014, 5010, 4987/DEL/2024 ACIT VS JAKSON LTD. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER & MRS. RENU JAUHRI, ACCOUNTANT MEMBER ITA No. 5010/DEL/2024; A.Y.: 2016-17 ITA No. 4987/DEL/2024; A.Y.: 2016-17 ACIT Vs Jakson Limited Delhi Jasola A-626, 6th Floor, DLF Floor Tower-A Jasola Delhi- 110025 (APPELLANT) (RESPONDENT) PAN No. AAACJ5347C ITA No. 5014/DEL/2024; A.Y.: 2016-17 Jakson Limited Vs DCIT-CC4 Jasola Jhandewalan Extension A-626, 6th Floor, DLF Floor Delhi Tower-A Jasola Delhi- 110025 (APPELLANT) (RESPONDENT) PAN No. AAACJ5347C Assessee b…

ACIT, New Delhi vs. Jakson Limited, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 5010/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR

Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

ACIT, New Delhi vs. Jakson Limited, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 4987/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR

Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

Vikram Brahmendra Satyajit Mulpuri, Krishna Dist vs. Income Tax Officer, Ward-3(1), Vijayawada

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 534/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.534/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Vikram Brahmendra Satyajit Vs. Income Tax Officer, Mulpuri, Ward-3(1), Krishna District. Vijayawada. Pan: Aonpm1893G (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm:

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 144BSection 147Section 148Section 148ASection 250Section 69A

…dam v. Savitribai Sopan Gujar and CCE v. Flock (India) (P) Ltd.)" (emphasis supplied by us) 16. We further find that the Hon'ble Supreme Court in its recent order passed in the case of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) had, inter alia, observed that the order passed without jurisdiction is nullity. It was further observed that if a statute expressly confers a power or imposes a duty on a particular authority, then such power or duty must be exercised or performed by that authority itself. The Hon'ble Apex Court had further observed that any exercise of powe…

Krishnaveni Kokkula, Hyderabad vs. ITO., Ward-9(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 558/HYD/2025[2016-17]Status: DisposedITAT Hyderabad17 Dec 2025AY 2016-17

Bench: Us:

Section 147Section 69A

…dam v. Savitribai Sopan Gujar and CCE v. Flock (India) (P) Ltd.)" (emphasis supplied by us) 19. We further find that the Hon'ble Supreme Court in its recent order passed in the case of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) had, inter alia, observed that the order passed without jurisdiction is nullity. It was further observed that if a statute expressly confers a power or imposes a duty on a particular authority, then such power or duty must be exercised or performed by that authority itself. The Hon'ble Apex Court had further observed that any exercise of powe…

Shivi Mukesh Kumar, Mumbai vs. ACIT, Circle 22(1), Mumbai

In the result, the appeal is partly allowed as indicated above

ITA 5293/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Dec 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Jagadishshivi Mukesh Kumar Acit, Circle 22(1) D-1402, Hubtown Seasons, Mumbai Next To Fine Arts Society, Vs. Ramakrishna Chemburkar Marg, Chembur, Mumbai-400 071 Pan/Gir No. Aqapk 9881 H (Appellant) : (Respondent) Appellant By : Shri Dharan V. Gandhi – Advocate & Ms. Vinita A. Nara – Advocate Respondent By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 11.12.2025 Date Of Pronouncement : 17.12.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against The Order Dated 01.07.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Assessment Year (A.Y.) 2016-17. 2. Though, The Assessee Has Raised Multiple Grounds, However, At The Time Of Hearing, Ld. Counsel Appearing For The Assessee Specifically Drew Our Attention To Ground No. 6, Which Reads As Under: 6. The Sanction U/S. 151 Is Bad In Law & As A Result, The Reassessment Proceeding Is Bad In Law. 3. Referring To This Ground, Ld. Counsel Submitted, At The Very Outset, This Issue May Be Considered And, If Warranted The Other Issues Can Be Taken Up Thereafter. As Could Be Seen

For Appellant: Shri Dharan V. Gandhi – Advocate &For Respondent: Shri Arun Kanti Datta – CIT DR

Section 133ASection 143(3)Section 147Section 148Section 151Section 35(1)(ii)

…he provisions of section 151. 5 Shivi Mukesh Kumar vs. ACIT 7. The Petitioner has drawn our attention to the decision of the Hon'ble Supreme Court in the case of Union of India vs. Rajeev Bansal [2024] 167 taxmann.com 70 (SC)/[2024] 301 Taxman 238 (SC)/[2024] 469 ITR 46 (SC) and we deem it appropriate to refer to the said judgment where the Hon'ble Supreme Court has, while dealing with the issue of approval from the specified authority in terms of Section 151 of the Act, made the following observations: "iii. Sanction of the specified authority 73. Section 151 imposes a check upon the power of the Revenue to reop…

Income Tax Officer, Ward-44(1), Delhi vs. Savita Aggarwal, Delhi

ITA 800/DEL/2025[2015]Status: DisposedITAT Delhi17 Dec 2025

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaincome Tax Officer Vs. Savita Aggarwal Ward-44(1) A-147, Shankar Garden, Room No. 1804, 18Th Vikaspuri Floor, E-2 Block, Delhi – 110018 Spm Civic Centre Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacpa3523A Appellant .. Respondent

For Appellant: Sh. Suresh K.Gupta, CAFor Respondent: Sh. Om Prakash, Sr. DR

Section 147Section 148Section 149(1)Section 68

…P a g e | 1 Savita Aggarwal (AY: 2015-16) IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER & SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER Income Tax Officer Vs. Savita Aggarwal Ward-44(1) A-147, Shankar Garden, Room No. 1804, 18th Vikaspuri Floor, E-2 Block, Delhi – 110018 SPM Civic Centre Delhi – 110002 "थायीलेखासं./जीआइआरसं./PAN/GIR No: AACPA3523A Appellant .. Respondent Appellant by : Sh. Suresh K.Gupta, CA Respondent by : Sh. Om Prakash, Sr. DR Date of Hearing 11.12.2025 Date of Pronouncement 17.12.2025 O R D E R PER ANUBHAV SHARMA, JM: This appeal is pref…