approval under section 151 — 453 judgments | BharatTax

MAHESH PRAKASH BENDE,MUMBAI vs. INCOME TAX OFFICER CIRCLE 27(2), MUMBAI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 8028/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Mar 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarmahesh Prakash Ito Circle - 27(2), Bende 4Th Floor, Tower No. 6, 302, 3Rd Floor, Prithvi Vs. It Office, Vashi Park, Sector-30, Vashi Railway Station Navi Mumbai-400 075 Building, Navi Mubmai – 400 703 Pan/Gir No. Alnpb2531M (Applicant) (Respondent) Assessee By Shri Devendra Jain, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 25.02.2026 Date Of Pronouncement 20.03.2026

Section 142(1)Section 144Section 144BSection 147Section 148Section 151Section 249Section 249(3)Section 250

formed a belief that income chargeable to tax had escaped assessment within the meaning of section 147 of the Act. Accordingly, after obtaining approval under section 151 of the Act, a notice under section 148 dated 22.03.2021 was issued to the assessee requiring him to file the return of income

BHAGERIA FINANCE & INVESTMENT PRIVATE LIMITED ,DELHI vs. INCOME TAX OFFICER, WARD 4(1), DELHI, DELHI

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

ITA 8807/DEL/2025[2012-13]Status: DisposedITAT Delhi13 Mar 2026AY 2012-13

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklabhageria Finance & Investment Income Tax Officer, Private Limited, Ward-4(1), G-324, Gali No.6, Shiv Mandir Vs. Delhi. Road, Swaroop Nagar, Delhi-110042. Pan-Aaacb4130F (Appellant) (Respondent)

Section 143(3)Section 147Section 148Section 151

genuine, the delay is condoned. 2ITA No.8807/Del/2025 Bhageria Finance & Investment Pvt. Ltd. vs. ITO 3. It is the case of the assessee that approval under Section 151 of the Act shows certain inconsistencies indicating non-application of mind by both the authorities below. According to the assessee the form

GOPI KISHAN MAKHARIA,BHIWANI vs. ITO-1, BHIWANI

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

ITA 8727/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklaassessment Year: 2017-18 Gopi Kishan Makharia, Vs Ito-1, Shree Saraswati Spinning Mills, Bhiwani, Birla Colony, Tosham Road, Haryana. Bhiwani, Haryana. Pan: Abhpm8102F (Appellant) (Respondent) Assessee By : Shri S.S. Nagar, Ca Revenue By : Shri Ravi Kant Chaudhary, Sr. Dr Date Of Hearing : 12.03.2026 Date Of Pronouncement : 13.03.2026 Order Per Madhumita Roy, Jm:

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Ravi Kant Chaudhary, Sr. DR

Section 147Section 148Section 148ASection 151Section 250

case of Union of India vs Ashish Agarwal, reported in 444 ITR 1 and, therefore, the Ld. Assessing Officer was required to obtain approval under Section 151 of the Act under the new regime before passing an order under Section 148A(d) of the Act or issuing notice under Section ... Bansal (supra), since the reassessment has been made after elapse of more than three years from the end of the relevant assessment year, approval under Section 151(ii) is, therefore, required to be taken from the Principal Chief Commissioner of Income Tax or the Principal Director General of Income

PBG INTERNATIONAL PRIVATE LIMITED,NEW DELHI vs. INCOME TAX OFFICER , DELHI, DELHI

In the result, the appeal filed by the Assessee is allowed

ITA 2890/DEL/2024[2016-17]Status: DisposedITAT Delhi13 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarpbg International Private Income Tax Officer, Limited, Ward-19(1), C.R. Building, Cb-4B, Dda Flats, Vs. Delhi-110002. Munirka, Delhi-110067. Pan-Aabcp8752E (Appellant) (Respondent) Assessee By Shri Anil Goyal, Ca Ms. Harpreet Kaur Hansra Sr. Dr Department By 20.01.2026 Date Of Hearing Date Of Pronouncement 13.03.2026 O R D E R Per Vimal Kumar, Jm: This Appeal Filed By The Assessee Is Against Order Dated 29.04.2024 Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As 'The Ld. Cit(A)'] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As 'The Act'] Arising Out Of Assessment Order Dated 25.03.2022 Of The Ld. Assessing Officer U/S 147 R.W.S 144B Of The Act For Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Filed His Original Return Of Income On 14.10.2016 Declaring Total Income Of Rs.4,42,670/- Along With Computation Of Income, Auditors' Report & Audited Accounts Of The Assessee. Ld. Ao On Basis Of Incriminating & Tangible Information & After Following Due Process, Re-Opened Pbg International Pvt. Ltd. Vs. Ito

Section 142(1)Section 147Section 148Section 151Section 250Section 68Section 690

reasons recorded for reopening of the case. Accordingly, the AO provided copy of reasons recorded for reopening of the case along with approval under section 151 of Income Tax Act vide letter dated 26.01.2022.On completion of proceedings, Ld. AO passed order dated 25.03.2022 u/s 147 r.w.s 144B ... disregard of principles of natural justice, is void ab-initio. Relief may please be granted by quashing the reassessment proceedings. 6.3 That the approval under section 151 was accorded in mechanical and routine manner, without application of mind by the Joint CIT, Range 19, Delhi. 6.4 The learned

DAYA THOURANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-3(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed as per afore-stated terms

ITA 1/RPR/2026[2017-18]Status: DisposedITAT Raipur09 Mar 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.1/Rpr/2026 "नधा"रण वष" /Assessment Year : 2017-18 Daya Thourani Thourani Niwas, Near Mla Rest House, Tagore Nagar, Raipur-492 001 (C.G.) Pan: Ablpt6191R

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 143(3)Section 151Section 282Section 282A(1)

income-tax authority shall be deemed to be authenticated if name and designation is provided. In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more

SHREE SAI HOSPITALITY,MUMBAI vs. INCOME TAX OFFICER, WARD 2(1), MUMBAI, THANE

In the result, the appeal of the assessee is allowed

ITA 9019/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Mar 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2018-19 Shree Sai Hospitality Vs. Ito, Ward 2(1) C/32, Harias Dream Ashar It Park, 6Th Floor Park, Mira Bhayander Road No. 16Z, Wagle Road, Mira Road (E), Industraial Estate, Thane – Mira-Bhayandar – 400604. 401107. Pan/Gir No. Acyfs5492G (Applicant) (Respondent)

Section 144Section 144BSection 147Section 148Section 151Section 250Section 69

learned Departmental Representative further submitted that the assessee had not raised the present legal contention regarding the validity of approval under section 151 of the Act before the learned CIT(A). 12. We have carefully considered the rival submissions and perused the material available on record. The primary legal issue

SHRI GAURAV AGARWAL,DARJEELING vs. ITO, WARD 1(3),, SILIGURI

In the result, the appeal of the assessee is allowed

ITA 1887/KOL/2025[2015-2016]Status: DisposedITAT Kolkata06 Mar 2026AY 2015-2016

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 147Section 148Section 148ASection 250oSection 69A

states that income chargeable to tax has escaped assessment without mentioning what is the amount of income that has escaped assessment. Further, the approval under Section 151 of the Act which is annexed to the impugned order is of one Poonam Vijay Chhabria whose PAN number is also entirely different

EKTA MERCHANTS PVT. LTD.,KOLKATA vs. I.T.O., WARD - 5(1),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2651/KOL/2025[2019-2020]Status: DisposedITAT Kolkata05 Mar 2026AY 2019-2020

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 147Section 148Section 148ASection 250

states that income chargeable to tax has escaped assessment without mentioning what is the amount of income that has escaped assessment. Further, the approval under Section 151 of the Act which is annexed to the impugned order is of one Poonam Vijay Chhabria whose PAN number is also entirely different

JUEE SUDHIR GORE,MUMBAI vs. ITO WARD-42(2)(3) , MUMBAI

The appeal is allowed

ITA 5868/MUM/2025[2017-18]Status: DisposedITAT Mumbai02 Mar 2026AY 2017-18

Bench: Justice (Retd.) C.V. Bhadang & Shri Vikram Singh Yadav: A.Y. : 2017-18

For Appellant: Shri Kumar KaleFor Respondent: Ms. Nidhi Agarwal, Sr. DR

Section 144BSection 147Section 148Section 148ASection 149(1)(a)Section 149(1)(b)Section 151Section 56(2)(x)

Rs.1,83,909/-. 3. Nevertheless, the appellant challenged the same before the First Appellate Authority, inter alia, on the ground of absence of approval under Section 151 of the Act from the appropriate authority. It was also contended that the notice under Section 148 of the Act issued

DCIT CC 5(1), MUMBAI , MUMBAI vs. J KUMAR INFRAPROJECTS LIMITED, MUMBAI

In the result, the CO filed by the assessee stands allowed

ITA 2885/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Feb 2026AY 2015-16

Bench: Shri Sandeep Gosain, () & Shri Bijayananda Pruseth

Section 250Section 69C

appreciate that the Ld. Assessing Officer (AO) erred in issuing a Notice under section 148 of the Act without obtaining a properly signed approval under section 151 of the Act; hence the order is bad in law and without jurisdiction. 2. Without prejudice to the above ... income-tax authority shall be deemed to be authenticated if name and designation is provided. In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more

DCIT CC 5(1) MUMBAI , MUMBAI vs. J KUMAR INFRAPROJECTS LIMITED, MUMBAI

In the result, the CO filed by the assessee stands allowed

ITA 2884/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Feb 2026AY 2014-15

Bench: Shri Sandeep Gosain, () & Shri Bijayananda Pruseth

Section 250Section 69C

appreciate that the Ld. Assessing Officer (AO) erred in issuing a Notice under section 148 of the Act without obtaining a properly signed approval under section 151 of the Act; hence the order is bad in law and without jurisdiction. 2. Without prejudice to the above ... income-tax authority shall be deemed to be authenticated if name and designation is provided. In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more

DCIT CC 5(1), MUMBAI , BKC vs. J KUMAR INFRAPROJECTS LIMITED, ANDHERI

In the result, the CO filed by the assessee stands allowed

ITA 2883/MUM/2025[2013-14]Status: DisposedITAT Mumbai26 Feb 2026AY 2013-14

Bench: Shri Sandeep Gosain, () & Shri Bijayananda Pruseth

Section 250Section 69C

appreciate that the Ld. Assessing Officer (AO) erred in issuing a Notice under section 148 of the Act without obtaining a properly signed approval under section 151 of the Act; hence the order is bad in law and without jurisdiction. 2. Without prejudice to the above ... income-tax authority shall be deemed to be authenticated if name and designation is provided. In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more

G.T. REALITY PRIVATE LIMITED, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1, RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed as per afore-stated terms

ITA 95/RPR/2026[2016-17]Status: DisposedITAT Raipur25 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.95/Rpr/2026 "नधा"रण वष" /Assessment Year : 2016-17 G.T Reality Private Limited 23, G.T. Shopping Plaza, Avanti Bai Chowk, Kapa, Raipur (C.G.)-492 007 Pan: Aadcg9139N

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 143(3)Section 151Section 282Section 282A(1)

income-tax authority shall be deemed to be authenticated if name and designation is provided. In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more

RAMAN VASU THACHISARIL, KOLLAM, KOLLAM vs. ITO, WARD- JAGDALPUR, JAGDALPUR

In the result, appeal of the assessee is allowed

ITA 91/RPR/2026[2011-12]Status: DisposedITAT Raipur24 Feb 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.91/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Raman Vasu Thachisaril Ramanalayam Clappana, Kollam, Amrithapuri S.O-690 546 Kerala, India Pan: Adopt0795N

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 147Section 148Section 282A(1)

income-tax authority shall be deemed to be authenticated if name and designation is provided. In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more ... income-tax authority shall be deemed to be authenticated if name and designation is provided. In approval under Section 151 of the Act of 1961, name, designation and office is printed. Hence, submission of learned counsel for petitioner that approval is not digitally signed is also not sustainable, more