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 366,459 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 148Section 147Section 148ASection 151Section 149Section 144BSection 250Section 144
Read the full judgment

Issues it is cited on

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

Judgments citing Union of India v. Rajeev Bansal

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 13, Delhi

ITA 2308/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Oct 2025AY 2018-19

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

…e Act is solely founded on information /material emanating from search action u/s132 of the Act and it is not a case of general assessment based on routine or non search issues. Reference was made to Hon’ble Apex court decision in case of UOI vs Rajeev Bansal 469 ITR 46, where it has been held 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. Further, when a statute vests certain power in an authority to be exercised in a particular manner, then that authority has to exercise its power follow…

Deepak Agarwal, Delhi vs. DCIT, Central Circle-25, Delhi

ITA 2306/DEL/2025[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

…e Act is solely founded on information /material emanating from search action u/s132 of the Act and it is not a case of general assessment based on routine or non search issues. Reference was made to Hon’ble Apex court decision in case of UOI vs Rajeev Bansal 469 ITR 46, where it has been held 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. Further, when a statute vests certain power in an authority to be exercised in a particular manner, then that authority has to exercise its power follow…

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 25, Delhi

ITA 2305/DEL/2025[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

…e Act is solely founded on information /material emanating from search action u/s132 of the Act and it is not a case of general assessment based on routine or non search issues. Reference was made to Hon’ble Apex court decision in case of UOI vs Rajeev Bansal 469 ITR 46, where it has been held 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. Further, when a statute vests certain power in an authority to be exercised in a particular manner, then that authority has to exercise its power follow…

Dharampal Satyapal Ltd., New Delhi vs. ACIT Central Circle 29, New Delhi

ITA 5519/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2015-16 Dharampal Satyapal Ltd., Vs. Acit, 98, Okhla Industrial Estate Central Circle-29, Phase Iii, New Delhi. Tehkhand, New Delhi – 110 020. Pan: Aaacd0132H (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi; Shri Satya Jeet Goel; & Shri Rajat Garg, Cas Revenue By : Shri Amit Jain, Cit-Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.10.2025 Order

For Appellant: Shri R.S. SinghviFor Respondent: Shri Amit Jain, CIT-DR
Section 115JSection 144CSection 147Section 148Section 148ASection 149Section 69ASection 80ISection 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : A : NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Assessment Year : 2015-16 Dharampal Satyapal Ltd., Vs. ACIT, 98, Okhla Industrial Estate Central Circle-29, Phase III, New Delhi. Tehkhand, New Delhi – 110 020. PAN: AAACD0132H (Appellant) (Respondent) Assessee by : Shri R.S. Singhvi; Shri Satya Jeet Goel; & Shri Rajat Garg, CAs Revenue by : Shri Amit Jain, CIT-DR Date of Hearing : 11.09.2025 Date of Pronouncement : 15.10.2025 ORDER PER ANUBHAV SHARMA, JM: This is an appeal preferred by the Assessee again…

Mitashi Edutainment Pvt. Ltd., Mumbai vs. The DCIT, Central Circle 6(4), Mumbai.

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 631/MUM/2025[2017-18]Status: DisposedITAT Mumbai14 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 148Section 151Section 250

…n. 3. At the very outset, Ld. AR submitted that the notice u/s 148 of the Act was issued without requisite permission u/s 151 of the Act. In this regard relied upon the decision of Hon’ble Supreme Court in the cases of Union of India Vs. Rajeev Bansal [2024] 469 ITR 46 (SC) and Ashish Agarwal, civil appeal No. 3005/2022 dated 04.05.2022. It was further argued by Ld. AR that the noticed issued is without containing DIN and was not issued by faceless AO. 4. On the contrary Ld. DR relied upon the decision of Hon’ble Gujarat High Court in the case of Dhanraj Govindram Kela Vs. ITO Special Civil Application No. 6387…

Mitashi Edutainment Pvt. Ltd., Mumbai vs. The DCIT, Central Circle 6(4), Mumbai.

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 630/MUM/2025[2016-17]Status: DisposedITAT Mumbai14 Oct 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 148Section 151Section 250

…n. 3. At the very outset, Ld. AR submitted that the notice u/s 148 of the Act was issued without requisite permission u/s 151 of the Act. In this regard relied upon the decision of Hon’ble Supreme Court in the cases of Union of India Vs. Rajeev Bansal [2024] 469 ITR 46 (SC) and Ashish Agarwal, civil appeal No. 3005/2022 dated 04.05.2022. It was further argued by Ld. AR that the noticed issued is without containing DIN and was not issued by faceless AO. 4. On the contrary Ld. DR relied upon the decision of Hon’ble Gujarat High Court in the case of Dhanraj Govindram Kela Vs. ITO Special Civil Application No. 6387…

Mitashi Edutainment Pvt. Ltd., Mumbai vs. The DCIT, Central Circle 6(4), Mumbai.

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 629/MUM/2025[2015-16]Status: DisposedITAT Mumbai14 Oct 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 148Section 151Section 250

…n. 3. At the very outset, Ld. AR submitted that the notice u/s 148 of the Act was issued without requisite permission u/s 151 of the Act. In this regard relied upon the decision of Hon’ble Supreme Court in the cases of Union of India Vs. Rajeev Bansal [2024] 469 ITR 46 (SC) and Ashish Agarwal, civil appeal No. 3005/2022 dated 04.05.2022. It was further argued by Ld. AR that the noticed issued is without containing DIN and was not issued by faceless AO. 4. On the contrary Ld. DR relied upon the decision of Hon’ble Gujarat High Court in the case of Dhanraj Govindram Kela Vs. ITO Special Civil Application No. 6387…

Mitashi Edutainment Pvt. Ltd., Mumbai vs. The DCIT, Central Circle 6(4), Mumbai.

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 628/MUM/2025[2014-15]Status: DisposedITAT Mumbai14 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 148Section 151Section 250

…n. 3. At the very outset, Ld. AR submitted that the notice u/s 148 of the Act was issued without requisite permission u/s 151 of the Act. In this regard relied upon the decision of Hon’ble Supreme Court in the cases of Union of India Vs. Rajeev Bansal [2024] 469 ITR 46 (SC) and Ashish Agarwal, civil appeal No. 3005/2022 dated 04.05.2022. It was further argued by Ld. AR that the noticed issued is without containing DIN and was not issued by faceless AO. 4. On the contrary Ld. DR relied upon the decision of Hon’ble Gujarat High Court in the case of Dhanraj Govindram Kela Vs. ITO Special Civil Application No. 6387…

Mudunuri Venkata Subbaraju, West Godavari vs. Income Tax Officer, Ward-1, Tanuku

In the result, appeal of the assessee is allowed

ITA 284/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.284/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Mudunuri Venkata Subbaraju V. Income Tax Officer – Ward – 1 5-205/2, Dommeru Aayakar Bhavan, 35-29-2 Near Reliance Tower Sajjapuram, Tanuku – 534211 Gowthaminagar S.O. Andhra Pradesh Kovvur, West Godavari – 534350 Andhra Pradesh [Pan:Cupps3676D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri C. Subrahmanyam, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparnavilluri, Sr.Ar

Section 143(2)Section 147Section 148ASection 250Section 69A

…] 174 taxmann.com 144 (SC) held as follows: - “4. The learned counsel appearing for the revenue with his usual fairness invited the attention of this Court to a three judge bench decision of this Court in Union of India and Ors. v. Rajeev Bansal, reported in 2024 SCC OnLine SC 2693, more particularly, paragraph 19(f) which reads thus:- “19. (f) The Revenue concedes that for the assessment year 2015- 2016, all notices issued on or after April 1, 2021 will have to be dropped as they will not fall for completion during the period prescribed under the Taxation and other Laws (Relaxation and Amendment of Certain Prov…

Manjusha Mittal, Delhi vs. ITO Ward 29(1), Delhi

Appeal of the assessee are allowed

ITA 5065/DEL/2025[2013-2014]Status: DisposedITAT Delhi13 Oct 2025AY 2013-2014

Bench: Sh. Satbeer Singh Godara

For Appellant: Sh. Abhishek Jain, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148

…the learned counsel appearing for the revenue. 4. The learned counsel appearing for the revenue with his usual fairness invited the attention of this Court to a three judge bench decision of this Court in Union of India and Ors. v. Rajeev Bansal, reported in 2024 SCC OnLine SC 2693, more particularly, paragraph 19(f) which reads thus:- "19. (f) The Revenue concedes that for the assessment year 2015- 2016, all notices issued on or after April 1, 2021 will have to be dropped as they will not fall for completion during the period prescribed under the Taxation and other Laws (Relaxation and Amendment of Certain Pro…

Manubhai Keshavlal & Co., Visnagar vs. The ITO, Ward-1, Patan

In the result, the appeal of the assessee is allowed

ITA 1446/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri Sudhakar Verma, Sr. DR
Section 147Section 148Section 28Section 7

…whichever is later) + G Date of new notice issued u/s 148. 27.07.2022 H Asst. Year : 2016-17 - 3– Note: Since the new notice u/s 148 is issued beyond the surviving period as explained by the Hon'ble Supreme Court in the case of UOI v. Rajeev Bansal -(2024) 469 ITR 46 (SC), the notice u/s 148 as well as the consequential reassessment order u/s 147 are bad in law. Reliance is further placed on the judgment of the Hon'ble Gujarat High Court in the case of Uday Dilipbhai Shah v. ITO in SCA No. 24695 of 2022. 4. The Revenue could not controvert the evidence submitted by the assessee. Accordingly, the appeal of the…

Na Roto Machine & Moulds India, Ahmedabad vs. The ACIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1349/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 133ASection 147Section 148ASection 270A

…e & Moulds India vs. ACIT Page 14 of 15 The Hon’ble Court held that since the notices under section 148 were issued beyond period of 'surviving time' as per direction of Supreme Court in Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC), such notices were invalid. 9.7 In view of the facts as discussed earlier and the judgement of the jurisdictional High Court, the impugned notice dated 26.08.2022 issued under Section 148 of the Act, is held to be invalid notice as the same was issued beyond the surviving period, as per the decision of Hon’ble Apex Court in the case of Rajiv…

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

…for A.Y. 2015-16 02. 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 decision 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. ITA No. 262& 263/KOL/2025 M/s Sunglow Vinimay Private Limited; A.Ys. 2014-15& 2015-16 03. The facts in brief are that the assessee filed the return of income on 30.09.2019, declaring total income at ₹66,01,840/- . The case of the assessee was reopened u/s 147 of the Act after the ld. AO received information that assessee re…

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

…for A.Y. 2015-16 02. 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 decision 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. 03. The facts in brief are that the assessee filed the return of income on 30.09.2019, declaring total income at ₹66,01,840/-. The case of the assessee was reopened u/s 147 of the Act after the Id. AO received information that assessee received accommodation entry in the form of share of investment amounting to ₹1,70,37,730…

Income Tax Officer, Piramal Chambers vs. Soni Ajay Jain, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3841/MUM/2025[2016-17]Status: DisposedITAT Mumbai08 Oct 2025AY 2016-17

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankar

For Appellant: Shri G. V. GindeFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 10(38)Section 147Section 148Section 148ASection 149Section 151Section 250

…e the Hon'ble Jurisdictional High Court in Ramesh Bachulal Mehta vs. Income Tax Officer, reported in (2025) 177 taxmann.com 606 (Bombay), after considering the decision of the Hon'ble Supreme Court in Union of India & Ors. v. Rajeev Bansal, reported in (2024) 469 ITR 46 (SC), held that after the expiry of three years from the end of the relevant assessment year, the Specified Authority as per the provisions of section 151 of the Act is Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. The relevant findings of the Hon'ble High Court, in the aforesaid decision, ar…

Tigerhill Tradelink Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the Appellant is Dismissed

ITA 956/KOL/2025[2014-2015]Status: DisposedITAT Kolkata03 Oct 2025AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 250Section 271BSection 68

…आयकर अपीलीय अधिकरण कोलकाता 'डी' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA 'D' BENCH, KOLKATA श्री जॉर्ज माथान, न्यायिक सदस्य एवं श्री राकेश मिश्रा, लेखा सदस्य के समक्ष Before SHRI GEORGE MATHAN, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER I.T.A. Nos.: 955 & 956/KOL/2025 Assessment Year: 2014-15 Tigerhill Tradelink Private Limited ITO, Ward-10(2), Kolkata Vs. (Appellant) PAN: AADCT9251A (Respondent) Appearances: Assessee represented by Department represented by Date of concluding the hearing Date of pronouncing the order : Deep Agarwal and Shubhankar Ghosh, AR. : S.B. Chakraborthy,…

Tigerhill Tradelink Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the Appellant is Dismissed

ITA 955/KOL/2025[2014-2015]Status: DisposedITAT Kolkata03 Oct 2025AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 250Section 271BSection 68

…आयकर अपीलीय अधिकरण कोलकाता 'डी' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D' BENCH, KOLKATA श्री जॉर्ज माथान, न्यायिक सदस्य एवं श्री राकेश मिश्रा, लेखा सदस्य के समक्ष Before SHRI GEORGE MATHAN, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER I.T.A. Nos.: 955 & 956/KOL/2025 Assessment Year: 2014-15 Tigerhill Tradelink Private ITO, Ward-10(2), Kolkata Limited Vs. (Appellant) PAN: AADCT9251A (Respondent) Appearances: Assessee represented by Department represented by Date of concluding the hearing Date of pronouncing the order : Deep Agarwal and Shubhankar Ghosh, AR. : S.B. Chakraborthy,…

Garje Rudrappa Jayanna, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result, appeals filed by the assessee are partly allowed

ITA 1079/BANG/2025[2018-19]Status: DisposedITAT Bangalore03 Oct 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 147Section 148Section 148ASection 149Section 271F

…IN INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER ITA Nos.1078, 1079/Bang/2025 Assessment Years : 2015-16, 2018-19 Mr. Garje Rudrappa Jayanna, Vs. ITO, Bi, 20 Hibc Sub Division Ward–1 & TPS, Krishnarajapet Town, Krishnarajpet Mandya. (Rural) Mandya, Krishnarapete S.O 571 426, Karnataka. PAN : AIHPJ 8444 Q APPELLANT RESPONDENT Assessee by : Smt. Suman Lunkar, CA Revenue by : Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue. Date of hearing : 11.09.2025 Date of Pronouncement : 03.10.2025 ORDER Per Laxmi Prasad Sahu, Accountant Member : Thes…

Garje Rudrappa Jayanna, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result, appeals filed by the assessee are partly allowed

ITA 1078/BANG/2025[2015-16]Status: DisposedITAT Bangalore03 Oct 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 147Section 148Section 148ASection 149Section 271F

…IN INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER ITA Nos.1078, 1079/Bang/2025 Assessment Years : 2015-16, 2018-19 Mr. Garje Rudrappa Jayanna, Vs. ITO, Bi, 20 Hibc Sub Division Ward–1 & TPS, Krishnarajapet Town, Krishnarajpet Mandya. (Rural) Mandya, Krishnarapete S.O 571 426, Karnataka. PAN : AIHPJ 8444 Q APPELLANT RESPONDENT Assessee by : Smt. Suman Lunkar, CA Revenue by : Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue. Date of hearing : 11.09.2025 Date of Pronouncement : 03.10.2025 ORDER Per Laxmi Prasad Sahu, Accountant Member : Thes…

Late Shri Jitendra Nagar Through His L/R Smt. Deepika Nagar, Baran vs. Income Tax Officer Ward Baran, Baran

In the result, appeal of the assessee is allowed

ITA 1382/JPR/2024[2016-2017]Status: DisposedITAT Jaipur01 Oct 2025AY 2016-2017

Bench: The Date Of Hearing.”

For Appellant: Shri Sidharth Ranka, AdvFor Respondent: Shri. Gautam Singh Choudhary, JCIT a
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 250Section 69A

…ction had to be obtained u/s. 151(ii) of the Act from the ld. Principal Chief Commissioner of Income Tax, Jaipur.The notice dated 25.07.2022 is thus bad in law in light of judgment of Hon’ble Supreme Court in the case of Union of India v. Rajeev Bansal [2024] 469 ITR 46 (SC) wherein it is held : iii. Sanction of the specified authority 73. Section 151 imposes a check upon the power of the Revenue to reopen assessments. The provision imposes a responsibility on the Revenue to ensure that it obtains the sanction of the specified authority before issuing a notice under Section 148. The purpose behind this procedural…