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“approval under section 151”

ReassessmentSection 151Section 151453 judgments

The decision most relied on for approval under section 151 is CIT v. S. Goyanka Lime & Chemical Ltd. (64 Taxmann.com 313), cited in 340 judgments on BharatTax.

Leading authorities on approval under section 151

CIT v. S. Goyanka Lime & Chemical Ltd.
64 Taxmann.com 313 · 2015 · Supreme Court
340
citing judgments

A mechanical approval by the prescribed authority under Section 151, made without independent application of mind, vitiates and renders the entire reassessment proceedings invalid. Such approvals, often indicated by brief, unreasoned endorsements, lead to the quashing of the reopening of assessment.

Kankanala Ravindra Reddy v. ITO
156 Taxmann.com 178 · 2023 · High Court
213
citing judgments

A notice issued under section 148 of the Income Tax Act is invalid if the Income Tax Department fails to follow the prescribed procedures, including obtaining the necessary approvals under section 151 or adhering to the faceless assessment scheme mandates under section 151A.

Madhya Pradesh in CIT v. S. Goyanka Lime & Chemicals Ltd.
56 Taxmann.com 390 · 2015 · High Court
188
citing judgments

A sanction for issuing a notice under section 148 is invalid if the sanctioning authority grants approval mechanically, merely recording 'Yes, I am satisfied' without proper application of mind to the reasons for reassessment. The authority must demonstrate proper consideration to fulfill the statutory obligation under section 151.

Narayanappa v. CIT
63 ITR 219 · 1967 · Supreme Court
187
citing judgments

The approval required from a higher authority under section 153D of the Income Tax Act is an administrative act, not a quasi-judicial one. Consequently, an opportunity of hearing is not required to be given to the assessee at the stage of obtaining such approval, provided the approving authority is competent.

CIT v. SPL’s Siddhartha Ltd.
345 ITR 223 · 2012 · High Court
164
citing judgments

Reassessment proceedings under Section 147 are invalid if the sanction required under Section 151 is obtained mechanically, without independent application of mind by the sanctioning authority, or is based on borrowed satisfaction.

Sabh Infrastructure Ltd. v. ACIT
398 ITR 198 · 2017 · High Court
137
citing judgments

Sanction under Section 151 granted in a mechanical manner, without application of mind, vitiates reassessment proceedings under Sections 147 and 148. The court also laid down guidelines for the Revenue to follow when reopening assessments, emphasizing the need to provide reasons and approval documentation to the assessee.

Verma Roadways v. ACIT
75 ITD 183 · 2000 · ITAT
130
citing judgments

Approval for assessment orders requires proper and thorough scrutiny and application of mind by the approving authority, involving an enquiry and judicial approach.

Sheo Nath Singh v. AAC
82 ITR 147 · 1971 · Supreme Court
129
citing judgments

To initiate reassessment under Section 147/148, the Income Tax Officer must have an honest and reasonable 'reason to believe' that income has escaped assessment, based on cogent grounds and not mere suspicion. Reassessment is invalid if based only on a lack of analysis during the original assessment without new material.

Judgments citing approval under section 151

DCIT CC 5 1 Mumbai, Mumbai vs. J Kumar Infraprojects Ltd, Mumbai

ITA 4587/MUM/2024[2022-23]Status: DisposedITAT Mumbai03 Jul 2025AY 2022-23

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation of section 151A ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon'ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

DCIT CC 5 1 Mumbai, Mumbai vs. J Kumar Infraprojects Ltd, Mumbai

ITA 4585/MUM/2024[2016-17]Status: DisposedITAT Mumbai03 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation of section 151A ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon'ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4153/MUM/2024[2020-21]Status: DisposedITAT Mumbai03 Jul 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation of section 151A ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon'ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle-5(1), Mumbai

ITA 4152/MUM/2024[2021-22]Status: DisposedITAT Mumbai03 Jul 2025AY 2021-22

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation of section 151A ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon'ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4151/MUM/2024[2022-23]Status: DisposedITAT Mumbai03 Jul 2025AY 2022-23

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation of section 151A ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon'ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

J Kumar Infraprojects Limited, Mumbai vs. The Dy Commissioner of Income Tax Central Circle -5(1), Mumbai

The Appeal of the Assessee is partly allowed and that of the department is dismissed

ITA 4150/MUM/2024[2019-20]Status: DisposedITAT Mumbai03 Jul 2025AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation of section 151A ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon'ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

J Kumar Infraprojects Limited, Mumbai vs. The Dy. Commissioner of Income Tax Central Circle -5(1), Mumbai

ITA 4149/MUM/2024[2018-19]Status: DisposedITAT Mumbai03 Jul 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation of section 151A ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon'ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

J Kumar Infraprojects Limited, Mumbai vs. The Dy. Commissioner of Income Tax Central Circle -5(1), Mumbai

ITA 4148/MUM/2024[2017-18]Status: DisposedITAT Mumbai03 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation of section 151A ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon'ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

J Kumar Infraprojects Limited, Mumbai vs. The Dy. Commissioner of Income Tax Central Circle -5(1), Mumbai

ITA 4147/MUM/2024[2016-17]Status: DisposedITAT Mumbai03 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

registry on 29.11.2024: “1. The Ld. AO erred in issuing a Notice under section 148 of the Act by obtaining a properly signed approval under section 151 of the Act. 6 J Kumar Infraprojects Ltd. 2. The Ld. AO erred in issuing a Notice u/s.148 of the Act in violation ... Krishi Kendra v. Union of lndia (2022) 444 ITR 584, wherein the Hon’ble Court specifically dealt with the question of an unsigned approval under Section 151 of the Act. In para 14 of the judgment, itwas unequivocally held thatanapproval bearing thename, designation, and office of the authority, would

S.K. Bhatia & Sons HUF, Delhi vs. ITO, Ward- 34(1), Delhi

Appeal is allowed in above terms

ITA 1800/DEL/2025[2017-18]Status: DisposedITAT Delhi03 Jul 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 1800/Del/2025 : Asstt. Year: 2017-18 S. K. Bhatia & Sons Huf, Vs Income Tax Officer, A-197, Whs Timber Market, Kirti Ward-34(1), Nagar, Moti Nagar, New Delhi New Delhi-110015 (Appellant) (Respondent) Pan No. Aavhs7168G Assessee By: Sh. Ayush Garg, Ca & Sh. Aditya Garg, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 03.07.2025 Date Of Pronouncement: 03.07.2025 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1073655510(1) Dated 24.02.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ayush Garg, CA &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 13ASection 147Section 148Section 148ASection 151Section 29A

General or where there is no such authority, by Chief Commissioner or Director General. The determination of the specified authority for grant of approval under Section 151 of the Act depends on whether the notice under Section 148 of the Act has been issued after the expiry of three years

Income Tax Officer Ward 10(1) Delhi, Delhi vs. Aruna Gupta, Delhi

ITA 687/DEL/2025[2017-18]Status: DisposedITAT Delhi01 Jul 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 687/Del/2025 : Asstt. Year: 2017-18 Income Tax Officer, Vs Aruna Gupta, Ward-10(1), B-1/45, Safdarjung Enclave, New Delhi-110002 New Delhi-110029 (Appellant) (Respondent) Pan No. Aakpg2642L Co No. 49/Del/2025 : Asstt. Year: 2017-18 Aruna Gupta, Vs Income Tax Officer, B-1/45, Safdarjung Enclave, Ward-10(1), New Delhi-110029 New Delhi-110002 (Appellant) (Respondent) Pan No. Aakpg2642L Assessee By: Dr. Rakesh Gupta, Adv. & Sh. Deepesh Garg, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 01.07.2025 Date Of Pronouncement: 01.07.2025 Order This Revenue’S Appeal & Assessee’S Cross Objection Co No. 49/Del/2025 For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1071333531(1) Dated 18.12.2024, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 13ASection 147Section 148Section 148ASection 151Section 29A

General or where there is no such authority, by Chief Commissioner or Director General. The determination of the specified authority for grant of approval under Section 151 of the Act depends on whether the notice under Section 148 of the Act has been issued after the expiry of three years

Deepanshu Projects Private Limited, Delhi vs. ITO, Ward-7(1), C. R. Building

Appeal is allowed in above terms

ITA 1730/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Jun 2025AY 2016-17

Bench: Shri Satbeer Singh Godara

Section 147Section 148Section 149Section 149(1)Section 151Section 151(1)Section 151(2)Section 234BSection 40

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.1730/Del/2025

Kundan Rice Mills Limited, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-14, New Delhi

In the result, the appeals of the Revenue are dismissed and appeals of the

ITA 594/DEL/2024[2014-15]Status: DisposedITAT Delhi27 Jun 2025AY 2014-15

Bench: Shri S Rifaur Rahman

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Dayainder Singh, CIT (DR) &
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 69A

were initiated and notice under Section 148 read with section 147 was issued to assessee on 14.01.2021 after recording reasons and necessary approval under Section 151 of the Act. In compliance of notice 3 ITA Nos.548, 593, 573, 594, 1595 & 1363/Del/2024 under Section 148 of the Act, assessee filed return

Kundan Rice Mills Limited, New Delhi vs. Deputy Commisioner of Income Tax, Central Circle-14, New Delhi

In the result, the appeals of the Revenue are dismissed and appeals of the assessee are allowed

ITA 593/DEL/2024[2013-14]Status: DisposedITAT Delhi27 Jun 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Dayainder Singh, CIT (DR) &
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 69A

were initiated and notice under Section 148 read with section 147 was issued to assessee on 14.01.2021 after recording reasons and necessary approval under Section 151 of the Act. In compliance of notice on 20.01.2021 declaring total income of Rs.7,61,81,580/-. Notice under Section

Deputy Commissioner of Income Tax, New Delhi vs. Kundan Rice Mills Limited, Haryana

In the result, the appeals of the Revenue are dismissed and appeals of the assessee are allowed

ITA 573/DEL/2024[2014-15]Status: DisposedITAT Delhi27 Jun 2025AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Dayainder Singh, CIT (DR) &
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 69A

were initiated and notice under Section 148 read with section 147 was issued to assessee on 14.01.2021 after recording reasons and necessary approval under Section 151 of the Act. In compliance of notice on 20.01.2021 declaring total income of Rs.7,61,81,580/-. Notice under Section

Deputy Commissioner of Income Tax, New Delhi vs. Kundan Rice Mills Limited, Haryana

In the result, the appeals of the Revenue are dismissed and appeals of the assessee are allowed

ITA 548/DEL/2024[2013-14]Status: DisposedITAT Delhi27 Jun 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2013-14 Kundan Rice Mills Ltd., Vs. Dcit, E-4, Industrial Area, Central Circle 14, Panipat, Haryana New Delhi Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent) Assessment Year: 2014-15 Dcit, Vs. Kundan Rice Mills Ltd., Central Circle 14, E-4, Industrial Area, New Delhi Panipat, Haryana Pin: 132 103 Pan No. Aaack7098P (Appellant) (Respondent)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Dayainder Singh, CIT (DR) &
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 69A

were initiated and notice under Section 148 read with section 147 was issued to assessee on 14.01.2021 after recording reasons and necessary approval under Section 151 of the Act. In compliance of notice on 20.01.2021 declaring total income of Rs.7,61,81,580/-. Notice under Section

Shree Ramraja Homes Pvt.Ltd, Jhansi vs. DCIT, Circle 2(1)(1), Agra

In the result, the appeal of the assessee is partly allowed

ITA 205/AGR/2024[2017-18]Status: DisposedITAT Agra24 Jun 2025AY 2017-18

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwaldcit, Shree Ramraja Homes Circle-2(1)(1), Pvt. Ltd., Vs. Sanjay Place, Agra. 7, Om Building, New Road, Jhansi, Uttar Pradesh- 284002 Pan-Aapcs3955G (Appellant) (Respondent) Assessee By Shri Utsav Sehgal, Ca Department By Shri Shailendra Srivastava. Sr. Dr Date Of Hearing 22/05/2025 Date Of Pronouncement 24/06/2025 O R D E R [ Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) Delhi [‘Ld. Cit(A) In Short] Dated 28.03.2024, In Appeal No. Nfac/2016-17/10165707 For Assessment Year 2017- 18 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Income Tax Act, 1961 (The Act, Inshort) Dated 21.03.2022. 2. Brief Facts Of The Case Are That Assessee Is A Private Limited Company Engaged In The Business Of Real Estate & Filed Its Return Shree Ramraja Homes Pvt. Ltd. Vs. Dcit Of Income On 28.09.2017 Declaring Total Income At Rs.46,53,593/-. The Assessing Officer Has Information In Its Possession That Assessee Has Made Cash Deposit In Specified Bank Notes (Sbn) During The Demonetization Period Of Rs.34,00,000/-, Therefore, The Case Of The Assessee Was Reopened By Way Of Issue Of Notice U/S 148 Of The Act On 31.03.2021 After Recording The Reasons & Taking Necessary Approvals From The Competent Authority. The Assessee Has Not Filed Any Return Of Income In Response To Notice U/S 148 Nor Made Any Response To The Notices Issued By The Ao On Various Occasions Including Show Cause Notice Dated 08.03.2022. Therefore, The Ao Has Completed The Assessment U/S 144 Of The Act By Making Addition Of Rs.34,00,000/- By Treating The Same As Unexplained Money U/S 69A Of The Act & Further Invoked The Provisions Of Section 115Bbe Of The Act.

Section 115BSection 144Section 147Section 148Section 148ASection 151Section 250Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL AGRA BENCH: AGRA BEFORE SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER AND SHRI MANISH AGARWAL

Smt..Anuradha, Pathankot vs. Income Tax Officer Ward-6(1), Pathankot

In the result the appeal of the assessee is allowed

ITA 437/ASR/2024[2012-13]Status: DisposedITAT Amritsar24 Jun 2025AY 2012-13

Bench: Sh. Udayan Dasgupta & Sh. Brajesh Kumar Singh

Section 133(6)Section 147Section 148Section 151(1)Section 250

case of Tele performance 18. Global Service (P.) Ltd. v. ACIT (2024) 298 Taxman 769 (Bom)(HC) has held in this case where approval under section 151 was obtained and granted without application of mind as in the approval, quantum of income, which had escaped assessment, was mentioned

Saif Ali Mansoor Ali Khan Pataudi, Mumbai vs. CIT (Appeals)- Delhi, Mumbai

In the result, the assessee succeeded on primary submission of ld

ITA 2131/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Jun 2025AY 2016-17

Bench: Shri Pawan Singh & Smt. Renu Jauhri(Physical Hearing) Saif Ali Mansoor Ali Khan Pataudi Cit(A), Nfac, Delhi/ Acit, Flat No. 1001/02, Fortune Heights, 29Th Vs Circle-16(1), Mumbai Road, Bandra West, Mumbai-400050. [Pan No. Aahpk0520E] Appellant / Assessee Respondent / Revenue Assessee By Shri K.K. Lalkaka, Ca Revenue By Ms. Sujatha Iyangar, Sr. Dr Date Of Institution Of Appeal 28.03.2025 Date Of Hearing 02.06.2025 Date Of Pronouncement 11.06.2025 Order Under Section 254(1) Of Income Tax Act

Section 148Section 149(1)(b)Section 151Section 155Section 251Section 254(1)

that apart from challenging the validity of addition, the assessee has challenged the validity of issuance of notice under section 148 and its approval under section 151 of Income Tax Act. The ld. AR of the assessee submits that case of assessee for assessment year (A.Y.) 2016-17 was reopened

Ashok Kumar Jain, Meerut vs. PCIT, Ghaziabad

In the result, both the appeals filed by appellant/assessee are allowed

ITA 2627/DEL/2024[2013-14]Status: DisposedITAT Delhi06 Jun 2025AY 2013-14

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singhita No. 2627/Del/2024 Assessment Year: 2013-14 Ita No.2628/Del/2024 Assessment Year: 2014-15 Ashok Kumar Jain, Vs. Principal Cit, Prop. Mange Lal Prakash Ghaziabad Chand, 45-B Gupta Colony, (Uttar Pradesh) T.P. Nagar, Meerut Pin: 250002 Pan: Aeipj3089E (Appellant) (Respondent) Assessee By: Shri Piyush Agarwal, Ca Department By: Mr. Javed Akhtar, Cit (Dr) Date Of Hearing: 20.03.2025 Date Of Pronouncement: 06.06.2025 O R D E R Per Vimal Kumar: The Appeals Filed By The Appellant/Assessee Are Against Separate Orders Dated 27.03.2024 Of Learned Principal Commissioner Of Income-Tax(Appeals), Ghaziabad (Hereinafter Referred As ‘Ld. Pcit’ ) Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred As “The Act”) Arising Out Of Separate Assessment Orders, Both Dated 29.03.2022 Of National Faceless Appeal Centre(Nfac), Delhi (Hereinafter Referred As “Ld. Ao”) Under Section 147 R.W.S. 144B Of The Act For Assessment Years 2013-14 & 2014-15 Respectively.

For Appellant: Shri Piyush Agarwal, CAFor Respondent: Mr. Javed Akhtar, CIT (DR)
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 263Section 40Section 40A(3)

Notice under Section 143(2) of the Act dated 22.06.2021 was issued. Ld. AO issued reasons recorded for notice under Section 148 and approval under Section 151 for issue of notice u/s 148, to the assessee on 25.06.2021. The case was migrated to the "National Faceless Assessment Scheme