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“sanction under section 151”

ReassessmentSection 151Section 151259 judgments

RUPINDER SINGH DUGGAL,AHMEDABAD vs. THE ITO, WARD-5(3)(2), AHMEDABAD

In the result the appeal filed by the assessee is allowed

ITA 1921/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 147Section 148Section 148ASection 149Section 151Section 192Section 54Section 80C

passing the order under section 148A(d) without obtaining valid I.T.A No. 1921/Ahd/2025 A.Y. 2017-18 4 Rupinder Singh Duggal Vs. ITO sanction under section 151 of the Act, and therefore the reopening and all subsequent proceedings are bad in law and liable to be quashed. 2. The Ld. Assessing ... Officer has erred in law and on facts in not adhering the alleged sanction under section 151 of the Act while passing order under section 148A(d) of the Act, which is contrary to statutory requirements, thereby rendering the proceedings without jurisdiction and liable to be annulled. 5. We have

JIGNESH NATVERLAL PATEL (REPRESNTED BY LATE NATVERLAL NANUBHAI PATEL),MUMBAI vs. ITO WARD 24(3)(1), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 6769/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Mar 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawaljignesh Natverlal Patel Vs Ito Ward-24(3)(1), Mumbai (Represented By Late Piramal Chamber, Lalbaug, Natverlal Nanubhai Patel) Mumbai-400012 401 Adarsh Building, Rto Four Bunglows, Andheri (West), Mumbai-400053 Pan:Aaapp1767B Appellant Respondent

For Appellant: Shri Aditya RamchandranFor Respondent: Shri Sushil B. Shende (Sr DR)
Section 139(1)Section 147rSection 148Section 148ASection 149Section 151Section 151ASection 250

granted by the Ld. Principal Commissioner of Income Tax-20, Mumbai. The legal position with regard to the competent authority for granting sanction under section 151 of the Act, prior to its amendment by the Finance Act, 2023, is now well settled. The Hon’ble Bombay High Court in Alag ... supra) has categorically held that where the period of three years from the end of the relevant assessment year has expired, sanction under section 151(i) could not have been accorded by the Principal Commissioner, and such sanction renders the reassessment proceedings void ab initio. The said judgment, being rendered

ROHITKUMAR CHINUBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

ITA 1961/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

material facts, that the reopening was based on third-party material already available with the department for several years, and that the sanction under section 151 of the Act was invalid. On merits, the assessee submitted that that the addition was based solely on loose papers found from a third ... time, based on the same material, was argued to be nothing but a change of opinion. It was also contended that the sanction under section 151 was mechanical and invalid, as evident from the information obtained under the Right to Information Act, wherein no proper satisfaction was recorded

SAURABHBHAI ROHITBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

ITA 1960/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

material facts, that the reopening was based on third-party material already available with the department for several years, and that the sanction under section 151 of the Act was invalid. On merits, the assessee submitted that that the addition was based solely on loose papers found from a third ... time, based on the same material, was argued to be nothing but a change of opinion. It was also contended that the sanction under section 151 was mechanical and invalid, as evident from the information obtained under the Right to Information Act, wherein no proper satisfaction was recorded

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

1875/Hyd./2025 has been accorded by Addl CIT/JCIT(Range head in a mechanical manner. 7. On the facts and circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD, HYDERABAD

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

1875/Hyd./2025 has been accorded by Addl CIT/JCIT(Range head in a mechanical manner. 7. On the facts and circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

1875/Hyd./2025 has been accorded by Addl CIT/JCIT(Range head in a mechanical manner. 7. On the facts and circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section

DARSHANA JATIN SHAH ,MUMBAI vs. ITO WARD 19(1)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 7769/MUM/2025[2015-16]Status: DisposedITAT Mumbai18 Feb 2026AY 2015-16
Section 144Section 147Section 148Section 148ASection 151ASection 250Section 69Section 69A

raised by the\nassessee, including those relating to issuance of notice by the\nJurisdictional Assessing Officer under section 151A and alleged\ninfirmity in sanction under section 151, are rendered academic\nand are not adjudicated.\n25. Consequently, the assessment order dated 05.03.2024\npassed under section 147 read with section 144 read

JIYA EXIM PRIVATE LIMITED,KOLKATA vs. ITO, WARD 5(1),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2142/KOL/2025[2012-2013]Status: DisposedITAT Kolkata17 Feb 2026AY 2012-2013
Section 143(1)Section 144Section 147Section 148Section 150(1)Section 150(2)Section 151Section 151(1)Section 250

assessee in the said case\nhad restricted his challenge to the validity of notice under section 148 only on the\nground that sanction under section 151 was not valid and the basis for reasons\nfurnished by the Assessing Officer in the notice under section 148 was never in\ndispute. Keeping

AMAN GUPTA,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, LTU CHENNAI, CHENNAI

In the result, the appeal filed by the assessee is partly-allowed

ITA 2565/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Feb 2026AY 2016-17

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2565/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Shri Aman Gupta, The Deputy Commissioner A-1, Vrindavan Enclave, Vs. Of Income Tax, 189, Lloyds Road, Circle 1, Gopalapuram, Ltu, Chennai – 600 086. Chennai. Pan: Adzpa 0417D (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri V. Tharish, Ca ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 17.02.2026

For Appellant: Shri V. Tharish, CAFor Respondent: Ms. Gouthami Manivasagam
Section 147ASection 148Section 148ASection 250Section 69A

even a whisper about: i. the alleged mandatory requirement of issuance by the Faceless Assessing Officer (FAO), or ii. the alleged invalidity of sanction under section 151(ii). 26. Even in the first appeal before the Id. CIT(A), the assessee challenged the reopening only on general grounds (Grounds

M/S. ARMSTRONG ENERGY PVT LTD ,MUMBAI vs. THE DCIT 6(1)(1), MUMBAI

ITA 3395/MUM/2025[2008-09]Status: DisposedITAT Mumbai16 Feb 2026AY 2008-09

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarm/S Armstrong Energy Pvt. Vs. Dcit 6(1) (1), Mumbai Ltd. Room No. 504, 5Th 5Th Floor, Militia Apartment, Floor, Aayakar Bhavan, Mathur Pakhadi Road, M.K. Road, Mazgaon, Mumbai 400020 Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Acit 6(1) (1), Mumbai Vs. M/S Armstrong Energy Pvt. Room No. 504, 5Th Floor, Ltd. Aayakar Bhavan, M.K. 5Th Floor, Militia Road, Apartment, Mathur Mumbai 400020 Pakhadi Road, Mazgaon, Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Assessee By Shri Nishit Gandhi Revenue By Shri Rajesh Kumar Yadav (Cit-Dr) Date Of Hearing 10.12.2025 Date Of Pronouncement 16.02.2026 आदेश / Order Per Sandeep Gosain, Jm: M/S. Armstrong Energy Pvt. Ltd.

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 151(2)Section 251(1)(a)Section 68

independent examination, clearly demonstrates non- application of mind by the sanctioning authority. We are of the considered view that the requirement of obtaining sanction under section 151(2) of the Act is a mandatory safeguard intended to prevent arbitrary, unwarranted or mechanical reopening of completed assessments. Thus the provision casts

ACIT-6(1)(1), MUMBAI, MUMBAI vs. ARMSTRONG ENERGY PVT. LTD., MUMBAI

ITA 2940/MUM/2025[2008-09]Status: DisposedITAT Mumbai16 Feb 2026AY 2008-09

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarm/S Armstrong Energy Pvt. Vs. Dcit 6(1) (1), Mumbai Ltd. Room No. 504, 5Th 5Th Floor, Militia Apartment, Floor, Aayakar Bhavan, Mathur Pakhadi Road, M.K. Road, Mazgaon, Mumbai 400020 Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Acit 6(1) (1), Mumbai Vs. M/S Armstrong Energy Pvt. Room No. 504, 5Th Floor, Ltd. Aayakar Bhavan, M.K. 5Th Floor, Militia Road, Apartment, Mathur Mumbai 400020 Pakhadi Road, Mazgaon, Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Assessee By Shri Nishit Gandhi Revenue By Shri Rajesh Kumar Yadav (Cit-Dr) Date Of Hearing 10.12.2025 Date Of Pronouncement 16.02.2026 आदेश / Order Per Sandeep Gosain, Jm: M/S. Armstrong Energy Pvt. Ltd.

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 151(2)Section 251(1)(a)Section 68

independent examination, clearly demonstrates non- application of mind by the sanctioning authority. We are of the considered view that the requirement of obtaining sanction under section 151(2) of the Act is a mandatory safeguard intended to prevent arbitrary, unwarranted or mechanical reopening of completed assessments. Thus the provision casts

SURAT GOODS TRANSPORT PVT LTD,MUMBAI vs. DCIT CIRCLE 16(2), MUMBAI

ITA 7556/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Feb 2026AY 2018-19

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

Section 143(3)Section 144Section 144BSection 147Section 148Section 148ASection 154Section 68

approval. Therefore, on account of approval granted by a non- specified authority, who does not possess the authority to grant such permission, the sanction under section 151 turns invalid. Consequently, the 5 Surat Goods Transport Pvt. Ltd. notice issued under section 148 dated 07.04.2022 and further proceedings consequential to such

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 780/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

reopening and does not amount to a final or conclusive determination of the issue on merits. It is settled law that sanction under section 151 is neither a judicial nor a quasi-judicial order and cannot be equated with a conscious examination of the correctness or otherwise of the eventual

KARAN PRATAP SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, HARYANA

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 761/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

reopening and does not amount to a final or conclusive determination of the issue on merits. It is settled law that sanction under section 151 is neither a judicial nor a quasi-judicial order and cannot be equated with a conscious examination of the correctness or otherwise of the eventual

MUNISH KUMAR LEGAL HEIR LATE SH GURDEEP SINGH,VILL MANAKPUR, YAMUNANAGAR vs. ITO, WARD 5, YAMUNANAGAR

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 754/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

reopening and does not amount to a final or conclusive determination of the issue on merits. It is settled law that sanction under section 151 is neither a judicial nor a quasi-judicial order and cannot be equated with a conscious examination of the correctness or otherwise of the eventual

MADHU GREWAL,CHANDIGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH-1, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 603/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh11 Feb 2026AY 2019-20

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

reopening and does not amount to a final or conclusive determination of the issue on merits. It is settled law that sanction under section 151 is neither a judicial nor a quasi-judicial order and cannot be equated with a conscious examination of the correctness or otherwise of the eventual

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 576/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-2019

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

reopening and does not amount to a final or conclusive determination of the issue on merits. It is settled law that sanction under section 151 is neither a judicial nor a quasi-judicial order and cannot be equated with a conscious examination of the correctness or otherwise of the eventual

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 575/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-2019
For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

reopening and does not amount to a final or conclusive determination of the issue on merits. It is settled law that sanction under section 151 is neither a judicial nor a quasi-judicial order and cannot be equated with a conscious examination of the correctness or otherwise of the eventual

RAM NIWAS,FATEHABAD vs. INCOME TAX OFFICER, INCOME TAX OFFICE, SIRSA ROAD, INDUSTRIAL AREA, FATEHABAD

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 498/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

reopening and does not amount to a final or conclusive determination of the issue on merits. It is settled law that sanction under section 151 is neither a judicial nor a quasi-judicial order and cannot be equated with a conscious examination of the correctness or otherwise of the eventual

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