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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

Inderjyot Singh, New Delhi vs. ITO Ward 44(1), Delhi

Appeal is allowed in above terms

ITA 8758/DEL/2025[2017-18]Status: DisposedITAT Delhi22 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 8758/Del/2025 : Asstt. Year: 2017-18 Inderjyot Singh, Vs Income Tax Officer, 6/2, Dlf Indl. Area, Moti Nagar, Ward-44(1), New Delhi-110015 New Delhi-110002 (Appellant) (Respondent) Pan No. Abyps9796E Assessee By: Sh. Rajesh Dureja, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 22.01.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, New Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082168393(1) Dated 30.10.2025, In Proceedings U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Rajesh Dureja, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

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

Vikas Chandra HUF, Aligarh vs. ITO Ward-4(1)(1), Aligarh

In the result, the appeal of the assessee is allowed

ITA 450/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Pankaj Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 139(1)Section 147Section 148Section 148ASection 151

independently on the basis of material placed before it before grant of sanction. 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

Bilwa Infrastructure Limited, Hyderabad vs. ITO., Ward-1(1), Hyderabad

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 1362/HYD/2025[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 145Section 147Section 148Section 148ASection 151Section 151ASection 250

only observed that in the case of the assessee before them, i.e., for AY 2018-19 the specified authority for granting approval under section 151 22 Bilwa Infrastructure Limited vs. ITO of the Act was the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General

Abdul Salam Mohamed Yasin, Mumbai vs. DCIT Circle 17(1), Mumbai

In the result, the appeal of the assessee is allowed on legal grounds

ITA 7502/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Jan 2026AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: 1. Assessment Year
Section 07Section 1Section 144Section 144BSection 147Section 148Section 148ASection 149(1)Section 151

terms that once the notice under section 148 is issued after expiry of three years from the end of the relevant assessment year, approval under section 151(ii) must necessarily be obtained from the higher specified authority, and any sanction accorded by the Principal Commissioner of Income-tax is legally

Rohit Goel, Delhi vs. DCIT, CC-20, Delhi

Appeal is allowed in above terms

ITA 8320/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 8320/Del/2025 : Asstt. Year: 2017-18 Rohit Goel, Vs Dcit, The Tax Chambers, Central Circle-20, Advocates & Legal Advisors, New Delhi-110055 C-177, Defence Colony, Lgf, New Delhi-110024 (Appellant) (Respondent) Pan No. Amvpg5611Q Assessee By: Ms. Swati Talwar, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2024-25/1073465261(1) Dated 19.02.2025, In Proceedings U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Ms. Swati Talwar, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

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

Ajay Nagpal, Delhi vs. ITO, Ward-48(1), Delhi

Appeal is allowed in above terms

ITA 8145/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Jan 2026AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 8145/Del/2025 : Asstt. Year: 2018-19 Ajay Nagpal, Vs Income Tax Officer, 15/10, East Patel Nagar, Ward-48(1), New Delhi-110008 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpn9871D Assessee By: Sh. Pranav Yadav, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2018-19 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081608419(1) Dated 09.10.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Pranav Yadav, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

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

Anil Kumar Jain, New Delhi vs. Dy. Commissioner of Income Tax, Central Circle-26, Jhandewalan, New Delhi

In the result, the appeal of the assessee is allowed

ITA 475/DEL/2025[2013-14]Status: DisposedITAT Delhi16 Jan 2026AY 2013-14

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

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

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

Sanjay Kumar vs. DCIT Circle-67(1), New Delhi

In the result, assessee’s appeal is allowed

ITA 5765/DEL/2025[2015-16]Status: DisposedITAT Delhi14 Jan 2026AY 2015-16

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singhassessment Year: 2015-16

Section 147Section 151

identical facts and circumstances of the matter, the undated approval by the PCIT and even the reasons recorded on the basis of which approval under Section 151 was taken, being undated the entire proceeding has been quashed. 3 5. Ld. DR at this juncture tried to differentiate the judgment only

Lng Amaethon LLP, Delhi vs. ITO Ward 14(1), Delhi

ITA 5302/DEL/2025[2016-17]Status: DisposedITAT Delhi14 Jan 2026AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shukla

For Appellant: Sh. Akash Ojha, AdvFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

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

M/S Padma Polychem Pvt. Ltd., Delhi vs. NFAC, Assessment Unit Itd, Delhi

Appeal is allowed in above terms

ITA 5301/DEL/2025[2014-15]Status: DisposedITAT Delhi14 Jan 2026AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5301/Del/2025 : Asstt. Year : 2014-15 M/S Padma Polychem Pvt. Ltd., Vs Cit(A)/Nfac, 528/1, Karkari Road, Vishwash Delhi Nagar, Delhi-110032 (Appellant) (Respondent) Pan No. Aafcp4479A Assessee By : Sh. Rakesh Kumar, Adv. & Sh. Akshay Gupta, Ar Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 14.01.2026 Date Of Pronouncement: 14.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2014-15, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1077228877(1) Dated 19.06.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Rakesh Kumar, Adv. &For Respondent: Ms. Ankush Kalra, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

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

Nimus Projects Limited, Delhi vs. DCIT, Central Circle-2, Noida

The appeal are disposed of as not pressed

ITA 5015/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

there is no information available with the Assessing Officer arising out of search carried out on Proform Interiors Pvt. Ltd.; that the approval under section 151 of the Act is also bad in law because the approval was granted in the mechanical manner without application of mind; that the approval

Nimbus Projects Limited, Delhi vs. DCIT, Central Circle-2, Noida

The appeal are disposed of as not pressed

ITA 5014/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

there is no information available with the Assessing Officer arising out of search carried out on Proform Interiors Pvt. Ltd.; that the approval under section 151 of the Act is also bad in law because the approval was granted in the mechanical manner without application of mind; that the approval

Numbus Projects Limited, Delhi vs. DCIT, Central Circle-2, Noida

The appeal are disposed of as not pressed

ITA 5013/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

there is no information available with the Assessing Officer arising out of search carried out on Proform Interiors Pvt. Ltd.; that the approval under section 151 of the Act is also bad in law because the approval was granted in the mechanical manner without application of mind; that the approval

Rakesh Divedi, Delhi vs. Income Tax Officer, Ward 43(6), Delhi

In the result, appeal of the Assessee is allowed

ITA 3290/DEL/2025[2009-10]Status: DisposedITAT Delhi09 Jan 2026AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwalrakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. Pan-Apcpd9179A (Appellant) (Respondent) Shri Pranshu Singhal, Ca Assessee By & Ms. Mansi Jain, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 09/01/2026 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 07.03.2025 In Appeal No.40/10204/2018-19 Arising Out Of The Order Passed By The Income Tax Officer, Ward-40(3) U/S 143(3) Of The Act (‘The Act’ For Short) Dated 20.12.2016 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Proprietor Of M/S Triambkay Gauri Impex. The Information Was Received By The Ao From Investigation Wing That There Were Cash Deposits In The Bank Account Of The Assesse With Icici Bank, However, Income Of The Assessee & Gross Receipt Has Not Rakesh Divedi Vs. Income Tax Officer Commensurate With The Cash So Deposited, Therefore, After Recording The Reason U/S 147, Notice U/S 148 Was Issued On 31.03.2016 After Obtaining Statutory Approval From The Pcit. Thereafter, Assessment Was Completed Vide Order Dated 20.12.2016 Wherein Total Addition Of Rs. 5,20,88,345/- Was Made U/S 68 Of The Act For Cash Deposited In The Bank Accounts By Holding The Same As Unexplained Cash Credits. 3. Against The Said Order, Assessee Has Filed An Appeal Before Ld. Cit(A) Who Vide Impugned Order Has Partly Allowed The Appeal Of The Assessee & Directed The Ao To Make Addition Of Peak Credit Of The Total Deposits In The Bank Accounts.

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68

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

Anant Bhalchandra Hendre, Mahad vs. Income-Tax Officer, Panvel

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

ITA 597/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Anup ShahaFor Respondent: Shri Vidya Ratna Kishore
Section 107Section 142(1)Section 147Section 148Section 148ASection 151Section 69A

facts and the circumstances of the case and in law, it be held that Assessment proceedings so completed are invalid since the requisite approval under section 151 (ii) of the Act is not taken. Accordingly, the assessment proceedings so initiated be kindly annulled and appellant be granted just and proper

Sanghi Textiles Private Limited, Hyderbad vs. ITO., Ward-3(1), Hyderabad

ITA 1311/HYD/2025[2014-15]Status: DisposedITAT Hyderabad07 Jan 2026AY 2014-15

Bench: Us:

Section 139(1)Section 143(2)Section 145Section 147Section 148Section 194ASection 250Section 37(1)

proper belief of income escapement. The appellant also challenges jurisdiction on technical grounds, including alleged non-furnishing of reasons and lack of approval under section 151. 5.1.2. It is an admitted fact that the appellant had failed to file the return of income u/s 139(1), despite being a company ... ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd. [(2007) 291 ITR 500 (SC)]. Further, the approval under section 151 was duly obtained and the reasons for reopening were recorded, as confirmed in the assessment order. The reassessment was within the prescribed time and squarely falls within the framework of section

ACIT Circle-28(1), New Delhi vs. Munjal Holdings, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5834/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 250Section 68

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

Bholenath Foods Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle- 4(2), New Delhi

The appeal of the assessee is disposed of in above terms

ITA 5777/DEL/2024[2012-13]Status: DisposedITAT Delhi07 Jan 2026AY 2012-13

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwalassessment Year : 2012-13 Bholenath Foods Limited, Vs. Income Tax Officer, Shop No.208, Ward 47(1), Bldg. No.2612/13, Naya Bazar, New Delhi. Delhi – 110 006. Pan: Aabcb3842P

For Appellant: Shri Shivam Yadav, Advocate &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 250Section 68

that change of opinion is not permitted in law. Hence,the re-assessment proceedings are liable to be quashed. 6. That the alleged approval under Section 151 of the Act is illegal and bad in law as same is given without application of mind and is also against the mandatory

Smita, Ranchi vs. ITO Ward 3(4), Chaibasa

The appeal of the assessee is allowed

ITA 266/RAN/2025[2018-19]Status: DisposedITAT Ranchi06 Jan 2026AY 2018-19

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 144BSection 147Section 148Section 151

learned counsel for the assessee submitted that though notice under section 148 was issued, the mandatory approval under section 151 of the Act was never supplied to the assessee along with the reasons recorded. From the assessment order also, it is evident that no copy of approval under section 151 ... furnished or served upon the assessee. Non-supply of approval under section 151 of Act vitiates the entire reassessment proceedings. The Ld. AR reliance was placed on the decision of the Hon’ble Delhi High Court in TIA Enterprises Pvt. Ltd. (468 ITR 5), wherein it was held that approval

Bishnu Transport Company, Dhanbad vs. DCIT/ACIT, Circle-1, Dhanbad

In the result, the appeal of the assessee is allowed

ITA 401/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(3)Section 147Section 148Section 151Section 151oSection 68

Supreme Court in NTPC vs. CIT (229 ITR 383). 5. The learned counsel for the assessee submitted that the approval under section 151 of the Act was granted in a routine and mechanical manner, without application of mind, which is evident from the approval sheet placed on record. The same ... sanction under section 151 invalidates the reassessment proceedings. 8. Since, in the present case of the assessee the very foundation of reopening, i.e., approval under section 151 of the Act, is invalid, the notice issued under section 148 of the Act and the consequent reassessment order passed under section