“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

Neelam Jain, Delhi vs. Income Tax Officer Ward 36(1) Civic Centre, New Delhi 110002, Delhi

Appeal is allowed

ITA 6261/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Neelam Jain, 374, Veer Apartment, Ward-36(1), Sector-103, Rohini, New Delhi Delhi Pan: Ajppj0908E (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

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

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

DCIT, Circle-4(2), New Delhi vs. Cds Infra Projects Ltd., New Delhi

In the result, the appeal of Revenue and cross-objection of Assessee are dismissed

ITA 1445/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Nov 2025AY 2012-13

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2012-13 Deputy Commissioner Of Income Vs. M/S. Cds Infra Projects Ltd., B-94, Tax, Circle 4(2), Okhla Industrial Area, Phase-Ii, New Delhi. New Delhi-110020 Pan :Aadcc0273D (Appellant) (Respondent)

Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)Section 271(1)(b)

Sarla Devi Nigam v. ITO-1 (1), Agra, 2018 (5) TMI 1540-ITAT, Agra, dated, 23-5-2018 7.12 Approval under section 151 of the Act is mechanical-Notice issued u/s. 148 without obtaining prior valid approval u/s. 151 of the Act will be considered as invalid and liable ... WARD-17 (4) NEW DELHI, 2024 (10) TMI 86-Income Tax Appellate Tribunal DELHI, DATED:- 30-9-2024 8.4 Approval under section 151 of the Act is mechanical-Notice issued u/s. 148 without obtaining prior valid approval u/s. 151 of the Act will be considered as invalid and liable

Sandeep Kumar Pandey, Handia vs. Income Tax Officer - 1(3), Prayagraj

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

ITA 136/ALLD/2025[2019-20]Status: DisposedITAT Allahabad21 Nov 2025AY 2019-20

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2019-20 Sandeep Kumar Pandey V. The Income Tax Officer 1(3) 012, Saitapur, Barethi Allahabad Handia, Allahabad (U.P) Tan/Pan:Blapp5054M (Appellant) (Respondent) Appellant By: Shri Shubham Singh, C.A. Respondent By: Shri A. K. Singh, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 21.05.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2019- 20. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits Of Rs.12,27,477/- In Bank Account No.0369000112307099 Maintained With Punjab National Bank & Of Rs.86,000/- In Bank Account Maintained With Bank Of Baroda During The Year Under Consideration. The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing

For Appellant: Shri Shubham Singh, C.AFor Respondent: Shri A. K. Singh, D.R

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

view of the ld. Assessing Officer, without considering the fact that notice under section 148 had been issued without providing a copy of approval under section 151, if any, as para 2.2 of circular no. F. No. 299/10/2022-Dir. (Inv. III)/611 dated 01.08.2023 which was binding on revenue

Om Prakash, Hathras vs. Income Tax Officer, Ward 4(3)(4), Hathras

In the result, the appeal of the assessee is allowed

ITA 153/AGR/2025[2011-12]Status: DisposedITAT Agra19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Om Prakash, Vs. Income Tax Officer, Village Baramai, Ward-4(3)(4), Sadabad, Hathras Hathras (Appellant) (Respondent) Pan: Dkbpp7713K

For Appellant: Shri Rajesh Malhotra, CAFor Respondent: Shri Anil Kumar, Sr. DR

Section 144Section 147Section 148Section 151

through proper channel for seeking approval in terms of Section 151 of the Act. For the sake of convenience, the said proforma seeking approval under Section 151 of the Act is reproduced below:- Om Prakash 6. I find that the assessee has furnished the entire bank statements for the period ... Learned AO that income of the assessee had escaped assessment is totally flawed. The Learned PCIT, Aligarh being the competent authority to grant approval under Section 151 of the Act ought Om Prakash to have verified this fact while sanctioning approval for reopening the assessment. The Ld PCIT not verifying

Ashok Rudraraju, Visakhapatnam vs. Income-Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 439/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 439/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) Ashok Rudraraju, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Visakhapatnam. Pan: Aqvpr4058L

For Appellant: Shri I. Kama Sastry, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 151(1)Section 151ASection 251(1)(a)Section 69A

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

Kineta Global Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

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

ITA 800/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, 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, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

For Appellant: Sri S. VenkateswarluFor Respondent: Dr. Narendra Kumar Naik

Section 147Section 148Section 148ASection 151Section 151ASection 250(6)

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

1.Income Tax Officer Ward 3(1), Kolkata vs. Anushreya Investment Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2543/KOL/2024[2011-12]Status: DisposedITAT Kolkata19 Nov 2025AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Income Tax Officer, Ward 3(1), Anushreya Investment Private Kolkata Limited P-7, Chowringhee Square, 5Th Floor, Mangalam-A, 24 4Th Floor, Aaykar Bhawan Hemanta Basu Sarani, Vs. Poorva, Kolkata-700069, Kolkata-700001, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aacca3658B Assessee By : Shri N.S. Saini, Ar Revenue By : Shri Susanta Saha, Dr Date Of Hearing: 31.10.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri N.S. Saini, ARFor Respondent: Shri Susanta Saha, DR

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

relevant AY, a further check by the further superior officer is contemplated." 12. We take note that request for approval under Section 151 of the Act in a printed format (Annexure P-6) was placed before the ACIT, who after according his satisfaction, placed the same before the PCIT. PCIT

Jd Jewellers, Delhi vs. ITO Ward-58(3), Delhi

In the result, the appeal of the assessee is allowed

ITA 2908/DEL/2025[2017-18]Status: DisposedITAT Delhi19 Nov 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Sudhir Kumarjd Jewellers, Vs. Income Tax Officer, C/O. Cs Anand, Adv, Ward-58(3), N-81, First Floor (Part- Delhi B), Defence Colony, Bhishma Pitamah Marg, New Delhi (Appellant) (Respondent) Pan: Aaffj2188K

For Appellant: Shri C. S. Anand, AdvFor Respondent: Shri Om Prakash, Sr. DR

Section 147Section 148Section 148ASection 151

whether the assumption of jurisdiction of the Learned AO under section 147 of the Act could be construed as valid when the approval under section 151 of the Act has been obtained from Learned Principal Commissioner of Income Tax (PCIT) instead of Learned Principal Chief Commissioner of Income Tax (PCCIT ... available on record. The issue involved is reopening of assessment for the Assessment Year 2017-18. For this purpose, the Learned AO obtained approval under section 151 of the Act from the Learned PCIT which fact is quite evident from the order passed under section 148 of the Act dated

Vijit Singh, Jaipur vs. ITO Ward 3(2) Jaipur, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1246/JPR/2025[2009-10]Status: DisposedITAT Jaipur17 Nov 2025AY 2009-10

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 147Section 234ASection 250

assessee encountering the ex- party assessment order as invalid and beyond jurisdiction. It is noted on perusal of the reasons recorded and approval under section 151 by the competent authority, it indicates that Pr. CIT has not applied his mind on the reasons recorded by lower authorities

Jamyang Khyentse Yeshi, Kangra, Himachal Pradesh vs. ACIT, DCIT, C.R. Building, Chandigarh

The appeal of the assessee is partly allowed

ITA 604/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh17 Nov 2025AY 2013-14

Bench: The Ld. Cit(A). The Ld. Cit(A), After Calling For A Remand Report Under Rule 46A, Recorded The Following Findings (Para 5.1 To 5.5 Of The Appellate Order):

For Appellant: Shri Nitin Kanwar, Advocate (Virtual)For Respondent: Shri Prem Singh, Addl. CIT, Sr. DR

Section 133(6)Section 147Section 148Section 69A

attention to page 9 and page 1 of the paper book, and it was submitted that the authorities below have mechanically granted the approval under section 151 of the Act, and therefore the assessment is required to be quashed. For the above-said purposes, he relied upon the decision

Income Tax Officer, Income Tax Department, Visakhapatnam vs. Quality Steel Shoppe Private Limited, Visakhapatnam

In the result, the Cross Objection No

ITA 454/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam14 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.454/Viz/2024 ("नधा"रण वष"/Assessment Year: 2018-19) Income Tax Officer, Vs. Quality Steel Shoppe Ward-2(1), Private Limited, Visakhapatnam. Visakhapatnam. Pan: Aaacq1115D (Appellant) (Respondent) C.O. No. 18/Viz/2024 (In आ.अपी.सं /454/Viz/2024) ("नधा"रण वष"/Assessment Year: 2018-19)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Sri Badicala Yadagiri

Section 144Section 144BSection 147Section 148Section 148ASection 151A

Income Tax Officer, Ward-1, Nellore vs. Venkata Ramanamma Sakamuri, Nellore

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

ITA 482/HYD/2025[2018-19]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-19

Bench: Us:

Section 147Section 148Section 148ASection 151

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

Rajbir Singh, Gurgaon vs. ACIT, Central Circle-19, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3104/DEL/2025[2013-14]Status: DisposedITAT Delhi14 Nov 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Rajbir Singh Vs. Acit 1625A, The Magnolia, Dlf Central Circle-19, City, Phase-V, Gurgaon, Khandewalan, Haryana New Delhi Pan: Aaups2176H Appellant Respondent Assessee By Sh. Amarjeet Singh, Ca Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 14/11/2025 Order

Section 13ASection 148Section 148ASection 151Section 29A

delay of 09 days in filing the present Appeal is hereby condoned. 3. The Ld. Counsel for the Assessee submitted that the approval under Section 151 of the Income Tax Act, 1961 ('Act' for short) has been obtained from Pr. Commissioner of Income Tax, Delhi-1, and should have ... where there is no such authority, by Chie f Commissioner or Director General. The determination o f the specified authority for grant of approval under Section 151 o f the A ct depend s on whether the notice under Section 148 of the A ct has been issued after

Guljar, Saharanpur vs. Income Tax Officer, Ward-3(5), Saharanpur

In the result, the appeal of the assessee in ITA No

ITA 3797/DEL/2024[2009-10]Status: DisposedITAT Delhi14 Nov 2025AY 2009-10

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Ankit Gupta, Adv [through VC]For Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

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

been filed and/nor return has been filed. Therefore, I have reason to believe that Rs. 55,12,000/- has escaped assessment.” The necessary approval under section 151(1) of the I.T. Act, 1961 has already been accorded by the Pr.CIT, Mzr. Vide letter F.No.Pr.CITMZR/ITO(Tech)/Approval u/s 148/151(1)/2015-16 dated

Bharti Mukesh Chandarana, Mumbai vs. Income Tax Officer (Int. Tax) Ward 2(1)(1), Mumbai

In the result, the ground No

ITA 4972/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Nov 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Bharti Mukesh Chandarana, Income Tax Officer Ward No. 64, Balasinor Society, S.V. Road, Vs 2(1)(1) Mumbai, Room No. 618, 6Th Floor, Kautilya Kandivali (West), Mumbai-400067, Maharashtra Bhawan, C-41 To C-43, G Block, [Pan No. Aacpc 4520F] Int Tax Ward, Bandra Kurla Complex, Bandra (East), Mumbai. Appellant / Assessee Respondent / Revenue

Section 132(4)Section 143(3)Section 144C(1)Section 144C(13)Section 147Section 148Section 151Section 153Section 153(2)Section 253

referred as to AO” is without jurisdiction and bad in law as the same has been issued without seeking valid Bharti Mukesh Chandarana approval under section 151 of the Act, hence, the notice under section 148 and the subsequent draft assessment order dated 31 March 2025 passed under section 144C ... Before DRP the assessee filed a detailed written submission in challenging the Bharti Mukesh Chandarana validity of reopening, issuing notice under section 148, approval under section 151 and addition of Rs. 2.50 Crore. The DRP on considering the submission of assessee, contents of assessment order, upheld the action of assessing

Harjinder Singh, Patiala, Punjab vs. ITO Ward, Sunam, Punjab

In the result, all the above appeals of the Assessee are allowed for statistical purposes

ITA 510/CHANDI/2025[2012-2013]Status: DisposedITAT Chandigarh12 Nov 2025AY 2012-2013

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

For Appellant: Shri Sudhir Sehgal, Advocate (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 250Section 282Section 69A

invalid service of notice under section 148 including defective affixture and non-compliance with section 282 and Rule 127; alleges that the approval under section 151 is mechanical; pleads that no valid notices under sections 142(1)/143(2) were served and that the entire proceedings are void; and, without

Harjinder Singh, Patiala, Punjab vs. ITO Ward, Sunam, Punjab

In the result, all the above appeals of the Assessee are allowed for statistical purposes

ITA 509/CHANDI/2025[2012-2013]Status: DisposedITAT Chandigarh12 Nov 2025AY 2012-2013

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

For Appellant: Shri Sudhir Sehgal, Advocate (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 250Section 282Section 69A

Harjinder Singh, Patiala, Punjab vs. ITO Ward, Sunam, Punjab

In the result, all the above appeals of the Assessee are allowed for statistical purposes

ITA 508/CHANDI/2025[2012-2013]Status: DisposedITAT Chandigarh12 Nov 2025AY 2012-2013

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

For Appellant: Shri Sudhir Sehgal, Advocate (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 250Section 282Section 69A

Harjinder Singh, Patiala, Punjab vs. ITO Ward, Sunam, Punjab

In the result, all the above appeals of the Assessee are allowed for statistical purposes

ITA 507/CHANDI/2025[2012-2013]Status: DisposedITAT Chandigarh12 Nov 2025AY 2012-2013

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

For Appellant: Shri Sudhir Sehgal, Advocate (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 250Section 282Section 69A

M/S Space Kraft Infrastructure (P) Ltd., Delhi vs. ACIT Central Circle-32, Delhi

In the result, assessee’s appeal is allowed

ITA 5749/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Nov 2025AY 2020-21

Bench: This Tribunal.

Section 132Section 139Section 147Section 148Section 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