approval under section 151 — 453 case laws

Seema Arora, Meerut vs. ITO Ward 2(3), Meerut

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

ITA 3932/DEL/2023[2012-13]Status: DisposedITAT Delhi08 Jul 2024AY 2012-13

Bench: Shri G.S. Pannu & Shri Vimal Kumarasstt. Year : 2012-13 Ms. Seema Arora, Vs. Ito, Ward-2(3), B-267, Shastri Nagar, Meerut Meerut Aayakar Bhawan, U.P. – 250004 Bhansali Ground, Delhi Road, (Pan: Abmpa8033G) Meerut, U.P.-250001 (Appellant) (Respondent) Appellant By : Shri P.S. Kashyap, Adv. Respondent By : Shri Ram Dhan Meena, Sr. Dr Date Of Hearing 20.06.2024 Date Of Pronouncement 08.07.2024

For Appellant: Shri P.S. Kashyap, AdvFor Respondent: Shri Ram Dhan Meena, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 148Section 151(2)Section 68

case. Notice u/s. 148 is a invalid notice as statutory notice u/s. 143(2) was not issued and also there is no proper approval under section 151(2) of the Act. Therefore, notice under section 148 is a invalid notice and assessment order passed u/.s 147 is void ab initio

Vishwesh Venkatraman, Norway and Uk vs. ITO (It) 4(3)(1), Air India Building Mumbai

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

ITA 1515/MUM/2024[2017-2018]Status: DisposedITAT Mumbai21 Jun 2024AY 2017-2018

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: S/Shri Harshavardhana Datar / Amit NegandhiFor Respondent: Shri Anil Sant, Addl.CIT-DR

Section 144C(13)Section 147Section 151Section 234CSection 3Section 69

Assessing Officer, Pursuant to directions from Ld. Dispute Resolution Panel (DRP-2), erred in framing the assessment order, in absence of the valid approval under section 151 to initiate reassessment, as approval is not of the specified authority u/s 151 and hence, reassessment initiated in absence of the valid approval ... Assessing Officer, Pursuant to directions from Ld. Dispute Resolution Panel (DRP-2), erred in framing the assessment order, in absence of the valid approval under section 151, as approval does not contain the Document Identification Number as specified in CBDT circular 19/2019 and hence, reassessment is initiated in absence

DCIT Circle-23(1), New Delhi vs. Ram Kumar Shokeen, New Delhi

In the result, the appeal of the Revenue is dismissed whereas the Cross Objection of the assessee is allowed

ITA 1009/DEL/2020[2011-12]Status: DisposedITAT Delhi13 Jun 2024AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Kumar

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Vivek Vardhan, Sr.DR

Section 143(3)Section 147Section 148Section 148(1)Section 148(2)Section 151

Section 151 of the Act. The approval as per requisition memo was accorded by the Pr.CIT, Delhi on 29.03.2018. Based on such approval under Section 151 of the Act, a notice dated 29.03.2018 was issued under Section 148 of the Act and served upon the assessee with a view ... with its purpose. The validity of the reassessment order is contingent upon a valid approval under s. 151. Where the requirement to grant approval under Section 151 of the Act is not fulfilled, the notice issued under Section 148 as a sequel to such sanction and resultant reassessment flowing therefrom

Vrp Telematics (P) Ltd., Delhi vs. DCIT, Central Circle, Meerut

In the result, the appeal of the assessee is allowed

ITA 3022/DEL/2022[2015-16]Status: DisposedITAT Delhi19 Apr 2024AY 2015-16

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year 2015-16

For Respondent: Shri Amit Katoch, Sr.DR

Section 143(3)Section 147Section 148Section 148(1)Section 148(2)Section 151Section 153C

years. Ostensibly, the re-assessment proceedings under Section 147 r.w. Section 148 in the instant case has been initiated without valid approval under Section 151 of the Act. 8. Needless to say, Section 151 of the Act serves as a cardinal safeguard for valid initiation of re-assessment proceedings ... motion. In the instant case as noted, the approval has been obtained from Addl. CIT not competent for granting requisite approval under Section 151 of the Act. Such remissness on the part of the AO have rendered the entire re-assessment proceedings invalid and bad in law. As held

Ganesh Shankar Pujare, Sindhudurg vs. Income Tax Officer, Ward, Kudal

In the result appeal filed by the assessee stands allowed for the statistical purposes

ITA 40/PUN/2024[2014-15]Status: DisposedITAT Pune18 Apr 2024AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.40/Pun/2024 िनधा"रण वष" / Assessment Year: 2014-15 Ganesh Shankar Pujare, Vs. Ito, Ward, Kudal. Bidyewadi, At Post Kalmath, Taluka Kankavli, Sindhudurg- 416602. Pan : Anipp5657R Appellant Respondent Assessee By Shri Tanzil R. Padvekar : Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 17.04.2024 Date Of Pronouncement : 18.04.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Is Filed By The Assessee Assailing The Order Dated 08.11.2023 Passed By Ld Cit(A) [‘Nfac’] For The Assessment Year 2014-15. 2. The Appellant Raised The Following Grounds Of Appeal :- “I. Legality & Validity Of Reassessment Proceeding; 1. On The Facts & In Law, The Re-Assessment Proceeding Initiated By The Ld. Assessing Officer Under Section 147 Of The Act Is Bad In Law As The Same Is Based On Suspicious & Incorrect Information. Hence, As The Formation Of Belief Is Based On Incorrect, Suspicious & Vague Facts Same Is Unsus Tainable In Eye Of Law. 2. On The Facts & In Law, There Is Serious Jurisdictional Requirement In The Reasons Recorded By The Assessing Officer As He

For Respondent: Shri Ramnath P. Murkunde

Section 143(3)Section 147Section 148Section 151

dated 31/03/2021 is bad in law. 4. On the facts and in law, the Sanctioning Authority seriously erred in giving approval under Section 151 of the Act to the proposal sent by the Assessing Officer as prima facie incorrect information was given in proposal and it indicate mechanically granting ... sanction/approval without due application of mind. Hence, mechanically giving approval under Section 151 of the Act by Authority is serious jurisdictional requirement and on this ground a notice issued by the Assessing Officer under Section 148 of the Act without jurisdictional, bad in law and needs to be quashed

Bharath Hi-Tech Builders Pvt. Ltd., Bangalore vs. Dy. CIT, Circle-1(1)(2), Bangalore

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

ITA 1034/BANG/2023[2009-10]Status: DisposedITAT Bangalore11 Mar 2024AY 2009-10

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

For Appellant: Sri.Inder Paul Bansal & Sri.Vivek BansalFor Respondent: Sri.Nilanjan Dey, Addl.CIT-DR

Section 147Section 148Section 151Section 153ASection 250

authorities below in support of this contention, he could not and did not point out any such observation so as to hold that approval under section 151 was obtained before issuing notice under section 148 of the Act. He fairly submitted that there is no finding recorded by either ... materials on record that such approval 16 Bharath Hi-Tech Builders Pvt.Ltd. was obtained, it would not be possible to assume that such approval under section 151 of the Act was obtained. The provisions contained in section 151 of the Act are indubitably mandatory in nature and since compliance thereof

Smt. Surinder Kaur Thapar (Legal Heir of Late Shri Amrit Singh Thapar), New Delhi vs. Deputy Commissioner of Income Tax, Circle-2(1), New Delhi

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

ITA 2103/DEL/2023[2010-11]Status: DisposedITAT Delhi08 Mar 2024AY 2010-11

Bench: Shri Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2010-11 Smt. Surinder Kaur Thapar Vs. Dcit, (Legal Heir Of Late Shri Amrit Circle-2(1), Singh Thapar) New Delhi. R-612, New Rajinder Nagar, New Delhi – 110 060 Pan Aaapt0790Q (Appellant) (Respondent)

For Appellant: Shri Lalit Mohan, CA &For Respondent: Shri Piyush Tripathi, Sr. DR

Section 131Section 143(2)Section 143(3)Section 147Section 148Section 151(1)Section 234CSection 68Section 69Section 69C

also appears as one of the beneficiary of fictitious profit/loss, notice under section 148 of the Act dated 27.03.2017 was issued after obtaining approval under section 151(1) of the Act. In response thereto, the assessee submitted that original return filed on 25.09.2010 for AY 2010-11 declaring income

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 767/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 759 To 762 & 764 To 767/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2013-14 To 2016-17)

For Appellant: Shri Prakash D. Shah & Shri SaiyamFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 142(1)Section 144B(8)Section 151Section 271(1)(b)

767/Ahd/2023 (Maheshbhai Prabhudas Gandhi) - 3 - the signed copy of the reason for the re-assessment and approval under Section 151 of the Act was asked for from the Ld. AO by the assessee by filing the reply dated 17.03.2022, a copy whereof has duly been submitted before us in each ... Further that, though the assessee made a request for supplying the signed copy for the reason of re-assessment and approval under Section 151 of the Act alongwith the response to the notice under Section 142(1) of the Act, penalty was imposed under Section

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 766/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 759 To 762 & 764 To 767/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2013-14 To 2016-17)

For Appellant: Shri Prakash D. Shah & Shri SaiyamFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 142(1)Section 144B(8)Section 151Section 271(1)(b)

767/Ahd/2023 (Maheshbhai Prabhudas Gandhi) - 3 - the signed copy of the reason for the re-assessment and approval under Section 151 of the Act was asked for from the Ld. AO by the assessee by filing the reply dated 17.03.2022, a copy whereof has duly been submitted before us in each ... Further that, though the assessee made a request for supplying the signed copy for the reason of re-assessment and approval under Section 151 of the Act alongwith the response to the notice under Section 142(1) of the Act, penalty was imposed under Section

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 765/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2014-15

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 759 To 762 & 764 To 767/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2013-14 To 2016-17)

For Appellant: Shri Prakash D. Shah & Shri SaiyamFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 142(1)Section 144B(8)Section 151Section 271(1)(b)

767/Ahd/2023 (Maheshbhai Prabhudas Gandhi) - 3 - the signed copy of the reason for the re-assessment and approval under Section 151 of the Act was asked for from the Ld. AO by the assessee by filing the reply dated 17.03.2022, a copy whereof has duly been submitted before us in each ... Further that, though the assessee made a request for supplying the signed copy for the reason of re-assessment and approval under Section 151 of the Act alongwith the response to the notice under Section 142(1) of the Act, penalty was imposed under Section

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 764/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 759 To 762 & 764 To 767/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2013-14 To 2016-17)

For Appellant: Shri Prakash D. Shah & Shri SaiyamFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 142(1)Section 144B(8)Section 151Section 271(1)(b)

767/Ahd/2023 (Maheshbhai Prabhudas Gandhi) - 3 - the signed copy of the reason for the re-assessment and approval under Section 151 of the Act was asked for from the Ld. AO by the assessee by filing the reply dated 17.03.2022, a copy whereof has duly been submitted before us in each ... Further that, though the assessee made a request for supplying the signed copy for the reason of re-assessment and approval under Section 151 of the Act alongwith the response to the notice under Section 142(1) of the Act, penalty was imposed under Section

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 762/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 759 To 762 & 764 To 767/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2013-14 To 2016-17)

For Appellant: Shri Prakash D. Shah & Shri SaiyamFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 142(1)Section 144B(8)Section 151Section 271(1)(b)

767/Ahd/2023 (Maheshbhai Prabhudas Gandhi) - 3 - the signed copy of the reason for the re-assessment and approval under Section 151 of the Act was asked for from the Ld. AO by the assessee by filing the reply dated 17.03.2022, a copy whereof has duly been submitted before us in each ... Further that, though the assessee made a request for supplying the signed copy for the reason of re-assessment and approval under Section 151 of the Act alongwith the response to the notice under Section 142(1) of the Act, penalty was imposed under Section

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 761/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 759 To 762 & 764 To 767/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2013-14 To 2016-17)

For Appellant: Shri Prakash D. Shah & Shri SaiyamFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 142(1)Section 144B(8)Section 151Section 271(1)(b)

767/Ahd/2023 (Maheshbhai Prabhudas Gandhi) - 3 - the signed copy of the reason for the re-assessment and approval under Section 151 of the Act was asked for from the Ld. AO by the assessee by filing the reply dated 17.03.2022, a copy whereof has duly been submitted before us in each ... Further that, though the assessee made a request for supplying the signed copy for the reason of re-assessment and approval under Section 151 of the Act alongwith the response to the notice under Section 142(1) of the Act, penalty was imposed under Section

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 760/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2014-15

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 759 To 762 & 764 To 767/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2013-14 To 2016-17)

For Appellant: Shri Prakash D. Shah & Shri SaiyamFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 142(1)Section 144B(8)Section 151Section 271(1)(b)

767/Ahd/2023 (Maheshbhai Prabhudas Gandhi) - 3 - the signed copy of the reason for the re-assessment and approval under Section 151 of the Act was asked for from the Ld. AO by the assessee by filing the reply dated 17.03.2022, a copy whereof has duly been submitted before us in each ... Further that, though the assessee made a request for supplying the signed copy for the reason of re-assessment and approval under Section 151 of the Act alongwith the response to the notice under Section 142(1) of the Act, penalty was imposed under Section

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 759/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 759 To 762 & 764 To 767/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2013-14 To 2016-17)

For Appellant: Shri Prakash D. Shah & Shri SaiyamFor Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 142(1)Section 144B(8)Section 151Section 271(1)(b)

767/Ahd/2023 (Maheshbhai Prabhudas Gandhi) - 3 - the signed copy of the reason for the re-assessment and approval under Section 151 of the Act was asked for from the Ld. AO by the assessee by filing the reply dated 17.03.2022, a copy whereof has duly been submitted before us in each ... Further that, though the assessee made a request for supplying the signed copy for the reason of re-assessment and approval under Section 151 of the Act alongwith the response to the notice under Section 142(1) of the Act, penalty was imposed under Section

Takrar Ranganatha Rao Nagashre, Bangalore vs. Income Tax Officer, Ward-3(2)(1), Bengaluru

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

ITA 1122/BANG/2023[2018-19]Status: DisposedITAT Bangalore14 Feb 2024AY 2018-19

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2018-19 Takrar Ranganatha Rao Nagashree Ito 20, Singapore Gardens Ward-3(2)(1) Vs. Bangalore 560 062 Bangalore Pan No.Aaipn8579M Assessee Respondent Assessee By : Shri Sreehari Kutsa, A.R. Revenue By : Shri Ganesh R. Ghale, Standing Counsel For Revenue. Date Of Hearing : 14.02.2024 Date Of Pronouncement : 14.02.2024 O R D E R Per Chandra Poojari: This Appeal By Assessee Is Directed Against Order Of Nfac For The Assessment Year 2018-19 Dated 29.12.2023 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). The Assessee Has Raised Following Grounds Of Appeal:

For Appellant: Shri Sreehari Kutsa, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Revenue

Section 143(2)Section 148Section 148ASection 151Section 250

Pursuant to the search action the Assessee was issued notice under section 148 of the Act on 23/03/2022 on the claim that prior approval under section 151 of the Act has been obtained from the specified authority. However, a copy of the prior approval was not supplied initially

Leelaben Kantilal Parekh, Mumbai vs. Income Tax Officer Ward 20(2)(1), Piramal Chamber, Mumbai

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

ITA 2926/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 Dec 2023AY 2011-12

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Piyush Chhajed a/wFor Respondent: Shri Nagnath B. Pasale

Section 133(6)Section 147Section 148Section 151Section 151(2)Section 250Section 69C

vide aforesaid application dated 06/12/2023, we find that the assessee has challenged the issuance of notice under section 148 in the absence of approval under section 151 of the Act from the appropriate authority under the Act. Further, the assessee has alleged that there was no independent application of mind ... same has been granted by the PCIT, who under the facts and circumstances of the present case was not authorised to grant the approval under section 151 of the Act. 7. Before proceeding further, it is pertinent to note the provisions of section 151 of the Act at the time

Shrifal Impex Private Limited, Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 250/SRT/2023[2014-15]Status: DisposedITAT Surat29 Dec 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

section 148 of the Act of 1961 Based on reasons to believe recorded by Assessing Officer in Annexure-A. The approving authority granted approval under section 151 of the Act of 1961. At this stage, this Court is to consider whether notices under section

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 191/SRT/2023[2012-13]Status: DisposedITAT Surat29 Dec 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

section 148 of the Act of 1961 Based on reasons to believe recorded by Assessing Officer in Annexure-A. The approving authority granted approval under section 151 of the Act of 1961. At this stage, this Court is to consider whether notices under section

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 190/SRT/2023[2011-12]Status: DisposedITAT Surat29 Dec 2023AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

section 148 of the Act of 1961 Based on reasons to believe recorded by Assessing Officer in Annexure-A. The approving authority granted approval under section 151 of the Act of 1961. At this stage, this Court is to consider whether notices under section

“approval under section 151”

Leading authorities on approval under section 151

Judgments citing approval under section 151

Seema Arora, Meerut vs. ITO Ward 2(3), Meerut

Vishwesh Venkatraman, Norway and Uk vs. ITO (It) 4(3)(1), Air India Building Mumbai

DCIT Circle-23(1), New Delhi vs. Ram Kumar Shokeen, New Delhi

Vrp Telematics (P) Ltd., Delhi vs. DCIT, Central Circle, Meerut

Ganesh Shankar Pujare, Sindhudurg vs. Income Tax Officer, Ward, Kudal

Bharath Hi-Tech Builders Pvt. Ltd., Bangalore vs. Dy. CIT, Circle-1(1)(2), Bangalore

Smt. Surinder Kaur Thapar (Legal Heir of Late Shri Amrit Singh Thapar), New Delhi vs. Deputy Commissioner of Income Tax, Circle-2(1), New Delhi

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

Maheshbhai Prabhudas Gandhi, Ahmedabad vs. The Income Tax Officer, Ward-5(3)(1), Ahmedabad

Takrar Ranganatha Rao Nagashre, Bangalore vs. Income Tax Officer, Ward-3(2)(1), Bengaluru

Leelaben Kantilal Parekh, Mumbai vs. Income Tax Officer Ward 20(2)(1), Piramal Chamber, Mumbai

Shrifal Impex Private Limited, Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat