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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

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

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

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

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

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

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

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

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, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 519/RJT/2024[2020-21]Status: DisposedITAT Rajkot24 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

material clearly state that the income has escaped assessment, hence there were enough tangible material to reopen the assessment. Apart from this, the approval under section 151 of the Act has been taken from the competent authority, hence, reopening of assessment is valid, and it is in accordance with

DCIT, Central Circle 1, Rajkot vs. Rk Infralink LLP, Rajkot

In the result, ground No. 3 in Revenue`s appeal in ITA No

ITA 518/RJT/2024[2019-20]Status: DisposedITAT Rajkot24 Feb 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 528/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/S. R K Infralink Llp The Dcit, Cc-1, R K Empire, Nr. Mavdi Circle, Vs. Aayakar Bhavan, Amruta Estate, M Rajkot 360001 G Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaxfr9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

Section 143(3)Section 147Section 148Section 250

material clearly state that the income has escaped assessment, hence there were enough tangible material to reopen the assessment. Apart from this, the approval under section 151 of the Act has been taken from the competent authority, hence, reopening of assessment is valid, and it is in accordance with

Sh. Randhir Singh, Sirsa vs. PCIT Rohtak, Rohtak

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

ITA 494/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh24 Feb 2026AY 2013-14

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

Section 143(3)Section 263

subsequent approval has been granted, under section 151 of the Act, by the Ld. PCIT. Normally, the Ld. PCIT would not grant subsequent approval under section 151 of the Act unless some inconsistency/illegality/mistake had not been noticed by him in the earlier approval under section 151 ... ground to this effect that the notice under Section 148 of the Act was bad in law for the particular fact that the approval under Section 151 of the Act, appearing at pages 68-71 of the paper book ought to have been issued under the signatures of the “PCIT

Surjeet Singh, Sirsa vs. PCIT, Rohtak

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

ITA 488/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

subsequent approval has been granted, under section 151 of the Act, by the Ld. PCIT. Normally, the Ld. PCIT would not grant subsequent approval under section 151 of the Act unless some inconsistency/illegality/mistake had not been noticed by him in the earlier approval under section 151 ... ground to this effect that the notice under Section 148 of the Act was bad in law for the particular fact that the approval under Section 151 of the Act, appearing at pages 68-71 of the paper book ought to have been issued under the signatures of the “PCIT

Sh. Paramjeet Singh, Sirsa vs. PCIT, Rohtak

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

ITA 290/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

subsequent approval has been granted, under section 151 of the Act, by the Ld. PCIT. Normally, the Ld. PCIT would not grant subsequent approval under section 151 of the Act unless some inconsistency/illegality/mistake had not been noticed by him in the earlier approval under section 151 ... ground to this effect that the notice under Section 148 of the Act was bad in law for the particular fact that the approval under Section 151 of the Act, appearing at pages 68-71 of the paper book ought to have been issued under the signatures of the “PCIT

Dhuni Chand HUF, Sirsa vs. PCIT, Rohtak

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

ITA 289/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

subsequent approval has been granted, under section 151 of the Act, by the Ld. PCIT. Normally, the Ld. PCIT would not grant subsequent approval under section 151 of the Act unless some inconsistency/illegality/mistake had not been noticed by him in the earlier approval under section 151 ... ground to this effect that the notice under Section 148 of the Act was bad in law for the particular fact that the approval under Section 151 of the Act, appearing at pages 68-71 of the paper book ought to have been issued under the signatures of the “PCIT

Sh. Kashmir Singh Sandha, Sirsa vs. PCIT, Rohtak

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

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

subsequent approval has been granted, under section 151 of the Act, by the Ld. PCIT. Normally, the Ld. PCIT would not grant subsequent approval under section 151 of the Act unless some inconsistency/illegality/mistake had not been noticed by him in the earlier approval under section 151 ... ground to this effect that the notice under Section 148 of the Act was bad in law for the particular fact that the approval under Section 151 of the Act, appearing at pages 68-71 of the paper book ought to have been issued under the signatures of the “PCIT

M/S Ganesh Dass HUF, Sirsa vs. PCIT, Rohtak

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

ITA 287/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

subsequent approval has been granted, under section 151 of the Act, by the Ld. PCIT. Normally, the Ld. PCIT would not grant subsequent approval under section 151 of the Act unless some inconsistency/illegality/mistake had not been noticed by him in the earlier approval under section 151 ... ground to this effect that the notice under Section 148 of the Act was bad in law for the particular fact that the approval under Section 151 of the Act, appearing at pages 68-71 of the paper book ought to have been issued under the signatures of the “PCIT

Sh. Arvail Singh, Sirsa vs. PCIT, Rohtak

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

ITA 286/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

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

Section 143(3)Section 263

subsequent approval has been granted, under section 151 of the Act, by the Ld. PCIT. Normally, the Ld. PCIT would not grant subsequent approval under section 151 of the Act unless some inconsistency/illegality/mistake had not been noticed by him in the earlier approval under section 151 ... ground to this effect that the notice under Section 148 of the Act was bad in law for the particular fact that the approval under Section 151 of the Act, appearing at pages 68-71 of the paper book ought to have been issued under the signatures of the “PCIT

M/S Mumbadevi Veyhicles, Mumbai vs. ITO Ward 41(4)(2), Mumbai

In the result the appeal of the assessee is allowed

ITA 7899/MUM/2025[2014-15]Status: DisposedITAT Mumbai24 Feb 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 151Section 250Section 271(1)(c)

reflected in Form 26AS, the Assessing Officer initiated reassessment proceedings. Notice under section 148 of the Act was issued on 30.03.2021 after obtaining approval under section 151 of the Act. In response to the said notice, the assessee filed its return of income on 30.04.2021 declaring total income

Firoj Alam, Bhilai, Durg vs. ITO-2(1), Bhilai, Durg

In the result, appeal of the assessee is allowed

ITA 830/RPR/2025[2018-19]Status: DisposedITAT Raipur19 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.830/Rpr/2025 "नधा"रण वष" /Assessment Year : 2018-19 Firoj Alam H. No.0, Hathkhoj, Indira Nagar, Bhilai-490 026 Pan: Bgmpa0920J

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 148Section 151Section 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

Dharmendra Rikhavchand Shah, HUF, Himatnagar vs. NFAC, Delhi Present Huris.the ITO, Ward-1, Himatnagar

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

ITA 2680/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR

Section 115BSection 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 148ASection 151Section 151A

since the assessment itself suffers from serious legal infirmities, including violation of faceless reassessment provisions under section 151A of the Act and mechanical approval under section 151 of the Act, the matter deserves to be restored to the file of the Assessing Officer for fresh adjudication after affording due opportunity

Society for Advancement in Education, Mussoorie vs. ITO Exemption Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 220/DDN/2025[2011-12]Status: DisposedITAT Dehradun18 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

basis of material placed before it before grant of sanction. 14. A perusal of the record reveals that the request for approval under section 151 of the Act in a printed format was placed before the Principal Chief Commissioner of Income-tax ("PCCIT") on March 20, 2023. The Principal Chief ... weighed in the grant of approval. The mere appending of the word "approved" by the Principal Chief Commissioner of Income-tax while granting approval under section 151 to the reopening under section 148 is not enough. While the Principal Chief Commissioner of Income-tax is not required to record elaborate

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 219/DDN/2025[2010-11]Status: DisposedITAT Dehradun18 Feb 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

basis of material placed before it before grant of sanction. 14. A perusal of the record reveals that the request for approval under section 151 of the Act in a printed format was placed before the Principal Chief Commissioner of Income-tax ("PCCIT") on March 20, 2023. The Principal Chief ... weighed in the grant of approval. The mere appending of the word "approved" by the Principal Chief Commissioner of Income-tax while granting approval under section 151 to the reopening under section 148 is not enough. While the Principal Chief Commissioner of Income-tax is not required to record elaborate

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 218/DDN/2025[2009-10]Status: DisposedITAT Dehradun18 Feb 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

basis of material placed before it before grant of sanction. 14. A perusal of the record reveals that the request for approval under section 151 of the Act in a printed format was placed before the Principal Chief Commissioner of Income-tax ("PCCIT") on March 20, 2023. The Principal Chief ... weighed in the grant of approval. The mere appending of the word "approved" by the Principal Chief Commissioner of Income-tax while granting approval under section 151 to the reopening under section 148 is not enough. While the Principal Chief Commissioner of Income-tax is not required to record elaborate

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

considering an identical issue has held in para 14 and 15 as under: "14. Perusal of the record reveals that the request for approval under section 151 of the Act in a printed format was placed before the Principal Chief Commissioner of Income-tax ["PCCIT"] on 20-3-2023. PCCIT ... material that may have weighed in the grant of approval. The mere appending of the word "approved by the PCCIT while granting approval under section 151 to the re-opening under section 148 is not enough. While the PCCIT is not required to record elaborate reasons, he has to record

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1884/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca 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 Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

notice under section 148 cannot be issued automatically to the searched person and the A.O needs to apply his mind and while seeking approval under section 151 of the Act from the specified authority, demonstrate that the information obtained/discovered during the search suggest that income has escaped, assessment under Explanation ... record reasons for issuance of notice and then such satisfaction should be forwarded to the specified authority for obtaining approval under section 151 of the Act. In the present case on hand, the A.O has not recorded any satisfaction, nor had taken any prior approval from

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1876/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca 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 Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

notice under section 148 cannot be issued automatically to the searched person and the A.O needs to apply his mind and while seeking approval under section 151 of the Act from the specified authority, demonstrate that the information obtained/discovered during the search suggest that income has escaped, assessment under Explanation ... record reasons for issuance of notice and then such satisfaction should be forwarded to the specified authority for obtaining approval under section 151 of the Act. In the present case on hand, the A.O has not recorded any satisfaction, nor had taken any prior approval from

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

para 14 and 15 as under: 62 ITA.Nos.1870 to 1875/Hyd./2025 "14. Perusal of the record reveals that the request for approval under section 151 of the Act in a printed format was placed before the Principal Chief Commissioner of Income-tax ["PCCIT"] on 20-3- 2023. PCCIT granted ... material that may have weighed in the grant of approval. The mere appending of the word "approved by the PCCIT while granting approval under section 151 to the re- opening under section 148 is not enough. While the PCCIT is not required to record elaborate reasons, he has to record

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), 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

para 14 and 15 as under: 62 ITA.Nos.1870 to 1875/Hyd./2025 "14. Perusal of the record reveals that the request for approval under section 151 of the Act in a printed format was placed before the Principal Chief Commissioner of Income-tax ["PCCIT"] on 20-3- 2023. PCCIT granted ... material that may have weighed in the grant of approval. The mere appending of the word "approved by the PCCIT while granting approval under section 151 to the re- opening under section 148 is not enough. While the PCCIT is not required to record elaborate reasons, he has to record