“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

Blackstone Overseas Pvt. Ltd., Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, the both appeals of the assessee are allowed

ITA 2027/KOL/2025[2018-2019]Status: DisposedITAT Kolkata18 Dec 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pradeep Dung Dung, DR

Section 143(1)Section 143(2)Section 148Section 148ASection 151

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

M/S. Blackstone Overseas Pvt. Ltd., Kolkata vs. I.T.O., Ward-5(1), Kolkata

In the result, the both appeals of the assessee are allowed

ITA 2026/KOL/2025[2016-2017]Status: DisposedITAT Kolkata18 Dec 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pradeep Dung Dung, DR

Section 143(1)Section 143(2)Section 148Section 148ASection 151

Kilaru Venkata Satish, Krishna Dist vs. DCIT, Central Circle-1(3), Hyderabad

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

ITA 933/HYD/2025[2018-19]Status: DisposedITAT Hyderabad17 Dec 2025AY 2018-19

Bench: Us), Which Reads As Under:

Section 147Section 148Section 148ASection 151Section 68

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 of the Act was the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General as a period of more than three

Laxmi Venkata Krishna Rice Corporation, Nalgonda vs. ITO, Ward-1, Suryapet

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

ITA 1700/HYD/2025[2017-18]Status: DisposedITAT Hyderabad17 Dec 2025AY 2017-18

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

Section 142(1)Section 144Section 147Section 148Section 148ASection 234ASection 69A

only observed that in the case of the assessee before them, i.e., for AY 2017-18 the specified authority for granting approval under section 151 of the Act was the Principal Chief Commissioner or Principal Director 22 Laxmi Venkata Krishna Rice Corporation vs. ITO General or Chief Commissioner or Director

Dy. Commissioner of Income Tax, Central Circle 3, Delhi vs. Pankaj Goel, Delhi

ITA 4159/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Dy. Commissioner Of Vs. Sh. Pankaj Goel, Income Tax, 662/3A, Ghati Road, Central Circle-3, Anand Paravt, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) With C.O. No.236/Del/2025 [Arising Out Of Ita No.4159/Del/2025] Assessment Year: 2017-18 Sh. Pankaj Goel, Vs. Dy. Commissioner Of Income 662/3A, Ghati Road, Tax, Anand Paravt, Central Circle-3, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) Assessee By Ms. Mansi Jain, Adv. Sh. Siddharth Bajaj, Adv. Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 17.12.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.4159/Del/2025 Along With Assessee’S Cross Objection C.O. No. 236/Del/2025 For Assessment & C.O. No.236/Del/2025

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

Ankita Badal Mittal, Mumbai vs. Ward 3(3)(1), Mumbai

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

ITA 5484/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Dec 2025AY 2017-18

Bench: Shri Sandeep Gosain

Section 147Section 148Section 149Section 151Section 250Section 68Section 69A

issued by the Jurisdiction AO instead of issuing the same in faceless manner. (b) Notice under section 148 was issued without obtaining requisite approval under section 151. (c) The Order is passed by the AO in violation of principal of natural justice as the appellant was asked to show cause ... after the expiry of the period of three years from the end of the relevant assessment year, the specified authority for grant of approval under section 151 is the Principal Chief Commissioner or the Principal Director General or the Chief Commissioner or Director General. In the present case, such approval

Shri Dinesh Kumar Sanghai, Mumbai vs. DCIT, Cir-23(3), Mumbai

ITA 6346/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Dec 2025AY 2016-17

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

Section 147Section 148Section 149Section 151Section 153CSection 69

period expires on 31 March 2020 and 31 March 2021 respectively. a. Finance Act 2021 substituted the old regime 8. Regarding validity of approval under section 151, it is categorically held by Hon'ble Apex Court in the case of Rajeev Bansal (supra) that after introduction of new regime which ... come into effect in 1st April 2021, the approval under section 151 should have been granted by the Sanctioning Authority specified under new regime which are different from those specified under the old regime, the relevant findings of the Hon'ble Court are as under: 75. After 1 April

Venkata Rama Krishnam Raju Chintalapati, Hyderabad vs. DCIT., Circle 8(1), Hyderabad

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

ITA 143/HYD/2025[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Us:

For Appellant: Shri KA Sai Prasad, CAFor Respondent: Shri Waseem UR Rehman

Section 147Section 148Section 148ASection 151

Income Tax Officer, Ward-1, Warangal vs. Shiva Kumar Thota, Warangal

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

ITA 996/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Mrs. U. Mini Chandran

Section 147Section 148Section 148ASection 43BSection 68

only observed that in the case of the assessee before them ie., for AY 2018-19 the specified authority for granting approval under section 151 of the Act was the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General as a period of more than three

Umar Daraj, Meerut vs. ITO Ward-1(2)(4), Meerut

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

ITA 3095/DEL/2025[2015-16]Status: DisposedITAT Delhi10 Dec 2025AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Umar Daraj, Vs. Ito, Ward 1(2)(4), 153/1, Hapur Road, Meerut. Umar Nagar, Meerut – 250 001 (Uttar Pradesh). (Pan : Ainpd8766H) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman:

For Appellant: Shri Sumit Lal Chandani, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CITDR

Section 142(1)Section 143(3)Section 148Section 151Section 40A

relaxations and Section 151 approvals, categorically held (paras 73, 74, 77 and 114(e)) that the extended timelines under TOLA applied only to approvals under Section 151(1), not to Section 151(2). For approvals under the old Section 151(2), the time limit expired on 31.03.2021, and only ... regime comes into effect from 01.04.2021.” 16. This position was reiterated in para 114(e), where the Supreme Court expressly ruled that approvals under Section 151(2) could not spill over 10 beyond 31.03.2021 and had to emanate from the JCIT. In the facts of the present case

Bipinkumar Rambhai Patel, Ahmedabad vs. The Pr. CIT-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 992/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Shri Siddhartha Nautiyalbipinkumar Rambhai Patel The Principal Vs. B/25, Ranchod Colony, Commissioner Of Maninagar, Income Tax, -1 Ahmedabad-380008 Ahmedabad [Pan: Aqapp5046M] (Appellant) .. (Respondent) Appellant By: Shri Mehul K. Patel, Advocate Respondent By: Shri R.P. Rastogi, Cit-Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 09.12.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-: -

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 151Section 263

requires to be quashed”. 3. The Assessing Officer issued notice under section 148 of the Income-tax Act on 29.03.2021, after obtaining due approval under section 151 from the Principal Commissioner of Income Tax, Ahmedabad–1, for alleged escapement of income amounting to Rs. 1,37,80,069/-. According

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 499/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &

Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

rival parties and have gone through the material placed on record. For the sake of clarity and also being pertinent, we reproduce the approval, under section 151 of the Act, as follows: ITA Nos. 498 & 499/Rjt/2025 Gopal Snacks Pvt. Ltd. vs. ACIT Gopal Snacks Pvt. Ltd. vs. ACIT Gopal Snacks ... ACIT 24 28. We have gone through the above approval under section 151 of the Act and noticed that it is neither digitally signed nor manually signed, hence the approval given by the Income Tax Authority is defective and consequently, the reassessment order passed by the assessing officer

Anju Agarwal, Agra vs. Income Tax Officer, Ward 2(1)(1), Agra

In the result, the appeal of the Assessee is allowed

ITA 320/AGR/2025[2019-20]Status: DisposedITAT Agra04 Dec 2025AY 2019-20

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Anju Agarwal, Vs. Income Tax Officer, D-26, Kamla Nagar, Ward-2(1)(1), Agra Agra (Appellant) (Respondent) Pan: Awtpa4297L Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

For Appellant: Shri K. K. Jain, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 133ASection 147Section 148Section 148ASection 151Section 68

Accordingly, notice under Section 148 of the Act stood issued to the Assessee on 27-3-2023 after taking prior approval under Section 151 of the Act from the competent authority. The reassessment stood completed under Section 147 r.w.s. 144B of the Act on 23-3- 2024 determining total income

Nanda Singh, Surajpur vs. ITO, Ward-1, Ambikapur

In the result, appeal of the assessee is allowed

ITA 677/RPR/2025[2011-12]Status: DisposedITAT Raipur04 Dec 2025AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.677/Rpr/2025 "नधा"रण वष" /Assessment Year : 2011-12 Nanda Singh Behind Civil Court, Ward No.8, Surajpur-492 229 (C.G.) Pan: Dbmps5756K

For Appellant: Shri S.R. Rao, AdvocateFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 147Section 151Section 282Section 282A(1)Section 292B

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

Nisha Fazal, Gautam Budh Nagar vs. ITO-4(3), Kanpur-01

In the result, appeal of the assessee is allowed

ITA 226/LKW/2024[2012-13]Status: DisposedITAT Lucknow04 Dec 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 1Section 142(1)Section 147Section 148Section 271(1)(b)

Appeal No.4: With most respectfully inform you that the reasons for reopening recorded by the Id. ITO-1(5), Kanpur and after obtained approval under section 151 of the Income Tax Act, from Id. Pr. CIT (1), Kanpur, that the reasons for reopening is as under: 1. "Above assessee ... reasons of reopening and notice under section 148 of the Income Tax Act, issued by the Id. ITO-1(5), Kanpur with the approval under section 151 of the Income Tax Act, and assessment proceeding and order was passed under section 144 / 147 of the Income Tax Act, is beyond

Alpesh Chandulal Modi, Mumbai vs. ITO Ward 16 (2) (1), Mumbai

Appeal of the assessee is allowed

ITA 5748/MUM/2025[2012-13]Status: DisposedITAT Mumbai02 Dec 2025AY 2012-13

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Surendra Mohan, Sr. DR

Section 133ASection 143(3)Section 148Section 151Section 250Section 292C

facts and in the circumstances of the case and in law, the Learned CIT(A) erred in dismissing the ground that the approval under section 151 of the Act, granted by the Joint Commissioner of Income Tax, Range 16(2), Mumbai, for initiation of reassessment proceedings, was accorded

Pothina Satyanarayana, Visakhapatnam vs. Income Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 568/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.568/Viz/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Pothina Satyanarayana, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Ahdpp1312N Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 19/11/2025 Hearing: घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 10/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 12/02/2024 For The Assessment Year 2018-19. The 2 Pothina Satyanarayana Vs. Ito

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 139(1)Section 147Section 148Section 148ASection 151Section 151ASection 54F

Satendra Pal Singh, New Delhi vs. ITO, Ward 36(1), Delhi

Appeal is allowed

ITA 6627/DEL/2025[2016-17]Status: DisposedITAT Delhi26 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godaraassessment Year: 2016-17 Sh. Satendra Pal Singh, Vs. Income Tax Officer, 155, Village-Dhaka, Ward-36(1), New Delhi Delhi Pan: Autps1163K (Appellant) (Respondent) Assessee By Sh. Satyajeet Goel, Adv. Department By Sh. Manoj Kumar, Sr. Dr

Section 13ASection 147Section 148Section 148ASection 151Section 29A

Rakesh, Copernicus Marg vs. ITO Ward 43, Delhi

Appeal is allowed

ITA 6481/DEL/2025[2018-19]Status: DisposedITAT Delhi25 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Vs. Income Tax Officer, Sh. Rakesh, D-65, Pinces Park, Ward-43, Copernicus Marg, Delhi Delhi Pan: Bwppr4036R (Appellant) (Respondent) Assessee By Sh. Shikhar Garg, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 13ASection 147Section 148Section 148ASection 151Section 29A

Sathi Bhai Sathyavrithan, Delhi vs. Income Tax Officer Ward 68(1), Civic Centre, New Delhi 110002, Delhi

Appeal is allowed

ITA 6274/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Sathi Bhai Sathyavrithan, Rz 31-32, Roshan Mandi Ward-68(1), Surya Kiran Hospital, New Delhi Najafgarh, New Delhi Pan: Ayqps2816L (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 13ASection 147Section 148Section 148ASection 151Section 29A