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“sanctioning authority”

ReassessmentSection 151Section 151426 judgments

The decision most relied on for sanctioning authority is CIT v. S. Goyanka Lime & Chemical Ltd. (64 Taxmann.com 313), cited in 340 judgments on BharatTax.

Leading authorities on sanctioning authority

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.

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.

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.

(P.) Ltd. v. ITO
221 ITR 538 · 1996 · Supreme Court
125
citing judgments

The sanction of a specified authority under Section 151 is a mandatory procedural check before issuing a notice under Section 148. This procedural safeguard aims to prevent mechanical reopening of assessments and harassment of the assessee.

PCIT v. NC Cables Ltd.
391 ITR 11 · 2017 · High Court
104
citing judgments

Approval for reassessment under Section 151 requires the approving authority to apply its mind and form an opinion, not merely endorse it mechanically. Additions under Section 68 cannot be made based on suspicion alone and require conclusive evidence.

Arjun Singh v. ADIT
246 ITR 363 · 2000 · High Court
102
citing judgments

For a valid reassessment, the sanctioning authority must apply its mind to the reasons for reopening the assessment under Section 147. A mechanical endorsement like 'I am satisfied' without considering the material amounts to non-application of mind and invalidates the sanction under Section 151.

Financial Services Pvt. Ltd. v. Dy. CIT
457 ITR 647 · 2023 · High Court
95
citing judgments

The amended Section 151 of the Income-tax Act, governing the sanction for reassessment proceedings under Sections 148 and 148A, applies to cases initiated under the new reassessment regime. The specified authority for granting such sanction becomes the Principal Chief Commissioner or Principal Director General if more than three years have elapsed from the end of the relevant assessment year.

Ghanshyam K. Khabrani v. ACIT
346 ITR 443 · 2012 · High Court
89
citing judgments

The reassessment proceedings are invalid if the required sanction under Section 151 of the Income Tax Act is not obtained from the statutorily designated authority or if the approval is granted mechanically without due satisfaction. Approval by a higher authority cannot substitute the satisfaction of the authority specified in Section 151.

Judgments citing sanctioning authority

Dindayal Agarwal, Berhampur vs. The Income Tax Officer, Ward-1, Berhampur.

In the result, the appeal of the assessee is allowed

ITA 471/CTK/2025[2017-18]Status: DisposedITAT Cuttack16 Mar 2026AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2016-17 Dindayal Agarwal Ito, Ward-1, Berhampur

For Appellant: Shri Pranaya Ku. Mishra, Prashant KumarFor Respondent: Shri Shakeer Ahamed, Sr. DR
Section 148Section 148ASection 151

order as well as the notice are issued on 22 April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151 (ii) of the Act. The proviso to Section 151 of the Act has been ... order as well as the notice are issued on 7th April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151 (ii) of the Act. The provisio to Section 151 has been inserted only with

Bmr Overseas Limited, Delhi vs. Deputy Commissioner of Income Tax Circle 4(2), C.R. Building Delhi 110002, Delhi

In the result the appeal of the assessee is allowed

ITA 6646/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Bmr Overseas Limited, Vs. Dcit, Circle 4(2), Zb-33/487, Plot No. 4 & 5, C.R. Building, Dilshad Garde New Delhi Industrial Area, Shahdara, Delhi – 110 095 [Pan No. Aafcb8509D) (Appellant) (Respondent)

Section 115BSection 143Section 147Section 148Section 151Section 156Section 157ASection 68

notice u/s. 148 was issued on 26.7.2022, i.e. after a period of three years from the end of the relevant assessment year. Accordingly, the sanctioning authority as per section 151(ii), should have been Principal Chie Commissioner or Principal Director General or Chief Commissioner or Director General. The said proposition

Shri Gandhi Maulana Azad Shramjivi Ashra, Kutch vs. Income Tax Officer, Exemption Ward 1, Rajkot

In the result, appeals of the assessee, are allowed

ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

built safeguard and check on exercise of powers by the Ld. AO u/s 147/148 of the Act. It is trite law that the sanctioning authority is expected to judiciously review and then record objective satisfaction and reflects independent application of mind. 7. It is respectfully submitted that satisfaction that ... accorded by the Ld. Designated Authority cannot be regarded as a valid satisfaction since it does not reflect due application of mind of the sanctioning authority. The satisfaction only leads to the inescapable conclusion that there was in reality, no independent application of mind by the Ld. Designated Authority. This

Shri Gandhi Maulana Azad Shramjivi Ashra, Kutch vs. Income Tax Officer, Exemption Ward 1, Rajkot

In the result, appeals of the assessee, are allowed

ITA 611/RJT/2025[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

built safeguard and check on exercise of powers by the Ld. AO u/s 147/148 of the Act. It is trite law that the sanctioning authority is expected to judiciously review and then record objective satisfaction and reflects independent application of mind. 7. It is respectfully submitted that satisfaction that ... accorded by the Ld. Designated Authority cannot be regarded as a valid satisfaction since it does not reflect due application of mind of the sanctioning authority. The satisfaction only leads to the inescapable conclusion that there was in reality, no independent application of mind by the Ld. Designated Authority. This

Shree Sai Hospitality, Mumbai vs. Income Tax Officer, Ward 2(1), Mumbai, Thane

In the result, the appeal of the assessee is allowed

ITA 9019/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Mar 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2018-19 Shree Sai Hospitality Vs. Ito, Ward 2(1) C/32, Harias Dream Ashar It Park, 6Th Floor Park, Mira Bhayander Road No. 16Z, Wagle Road, Mira Road (E), Industraial Estate, Thane – Mira-Bhayandar – 400604. 401107. Pan/Gir No. Acyfs5492G (Applicant) (Respondent)

Section 144Section 144BSection 147Section 148Section 151Section 250Section 69

statutory mandate contained in section 151(ii), where more than three years have elapsed from the end of the relevant assessment year, the sanctioning authority must be the Principal Chief Commissioner of Income Tax or equivalent authority, and not the Principal Commissioner of Income Tax. Thus, the approval granted ... order as well as the notice are issued on 7th April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151 (ii) of the Act. The provisio to Section 151 has been inserted only with

Shairul Impex, Mumbai vs. Assessment Unit Income Tax Department (Income Tax Officer Ward 19(3)(1)), Mumbai

ITA 6613/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Mar 2026AY 2014-15

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

Section 147Section 148Section 151A

escaped in the present matter. Accordingly notice under section 148 was issued on 19.04.2021 after recording reasons along with prior approval of the sanctioning authority. Subsequently, the procedure of reopening was initiated, as per amended regime following the decision of Union 3 ITA No.6613/Mum/2025 Shairul Impex of India vs. Ashish

Gopal Anil Kumar, Bangalore vs. DCIT, Central Circle-1(3), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 862/BANG/2025[2018-19]Status: DisposedITAT Bangalore05 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Ms. Pooja Maru, A.RFor Respondent: Sri Balusamy N., D.R
Section 132Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 37Section 44ASection 68

Authority of the action of the AO in reopening the assessment. However, the language of the provision does not confine the duty of the sanctioning authority to merely approve the proposed action of the AO in reopening the assessment but puts some more burdens before granting such sanction/approval ... word "satisfied" cast greater duty on such authority. The sanctioning authority has to satisfy himself that necessary prerequisite of section 147 of the Act that there is an escapement of income stood fulfilled; however in the present case the satisfaction itself was clearly on the wrong foundation that the assessee

Govindan Gnanavel, Nagapattinam vs. ITO, Ward-1(1), Trichy

In the result, the appeal of the assessee is allowed

ITA 3202/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.3202/Chny/2025 िनधा"रण वष" /Assessment Year: 2018-19

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Aswathy, JCIT
Section 147Section 148Section 148ASection 151Section 250Section 69A

notice u/s.148 of the Act came to be issued on 19.04.2022 for the A.Y. 2018-19. 41. The provisions of Section 151 defines the sanctioning authority and the relevant provisions as it stood at that point in time reads as under: “151. Specified authority for the purposes of section

S 1284 Thathaiyangarpatty Paccs Ltd., Namakkal vs. ITO, Ward-2, Namakkal

ITA 3172/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.3171 & 3172/Chny/2025 िनधा"रण वष" /Assessment Years: 2017-18 & 2018-19 S 1284 Thathaiyangarpatty Primary The Income Tax Officer, Agricultural Co-Operative Credit Vs. Ward-2, Society Ltd., Namakkal. Karaikuruchipudur P.O., Namakkal – 637 018. Pan: Aagas 9153H

For Appellant: Mr. A. Tamilamudan, C.A ,-For Respondent: Ms. Aswathy, JCIT
Section 139(1)Section 147Section 148Section 148ASection 151Section 250Section 69ASection 80P

notice u/s.148 of the Act came to be issued on 19.04.2022 for the A.Y. 2018-19. 41. The provisions of Section 151 defines the sanctioning authority and the relevant provisions as it stood at that point in time reads as under: “151. Specified authority for the purposes of section

S 1284, Thathaiyangarpatty Paccs Ltd., Namakkal vs. ITO, Ward-2, Namakkal

ITA 3171/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Mar 2026AY 2017-18

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.3171 & 3172/Chny/2025 िनधा"रण वष" /Assessment Years: 2017-18 & 2018-19 S 1284 Thathaiyangarpatty Primary The Income Tax Officer, Agricultural Co-Operative Credit Vs. Ward-2, Society Ltd., Namakkal. Karaikuruchipudur P.O., Namakkal – 637 018. Pan: Aagas 9153H

For Appellant: Mr. A. Tamilamudan, C.A ,-For Respondent: Ms. Aswathy, JCIT
Section 139(1)Section 147Section 148Section 148ASection 151Section 250Section 69ASection 80P

notice u/s.148 of the Act came to be issued on 19.04.2022 for the A.Y. 2018-19. 41. The provisions of Section 151 defines the sanctioning authority and the relevant provisions as it stood at that point in time reads as under: “151. Specified authority for the purposes of section

ITO, Ward-1(1), Kolkata vs. A P Trading and Finance Company Limited, Kolkata

In the result, the appeal of the revenue stands dismissed and the cross-objection of the assessee stands allowed

ITA 2801/KOL/2025[2016-17]Status: HeardITAT Kolkata02 Mar 2026AY 2016-17

Bench: Shri George Mathan & Shri Laxmi Prasad Sahuassessment Year: 2016-17 Ito, Ward-1(1), Kolkata A P Trading & Finance Company Limited Vs P-39, Princep Street, Kol – 700069. (Pan: Aadca8815B) (Appellant) (Respondent)

For Appellant: Shri Narendra Kedia, AdvocateFor Respondent: Shri Soumitra Ghosh, Sr. DR
Section 148Section 148ASection 151

order as well as the notice are issued on 22 April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151 (ii) of the Act. The proviso to Section 151 of the Act has been ... order as well as the notice are issued on 7th April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151 (ii) of the Act. The provisio to Section 151 has been inserted only with

Stp Enterprises, Tirunelveli vs. DCIT, Circle-1, Tirunelveli

The appeal of the assessee is allowed

ITA 3729/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3729/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 147Section 148Section 148ASection 151Section 250Section 69A

came to be issued on 19.04.2022 for the A.Y. 2018-19. STP Enterprises :- 3 -: 41. The provisions of Section 151 defines the sanctioning authority and the relevant provisions as it stood at that point in time reads as under: “151. Specified authority for the purposes of section 148 and section

Pradyumna Kumar Lath, Jharsuguda vs. Assistant Commissioner of Income Tax, Circle, Rourkela

In the result, appeal of the assessee stands allowed

ITA 820/CTK/2025[2016-17]Status: DisposedITAT Cuttack25 Feb 2026AY 2016-17

Bench: Shri George Mathan & Shri Madhusudan Sawdiaआयकर अपील सं/Ita No.820/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2016-2017) Vs Acit, Circle Rourkela, Rourkela Pradyumna Kumar Lath, At-Dalki, Po: Jharsuguda, Dist: Jharsuguda-768201 Pan No. :Aaopl 7797 H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate राजस्व की ओर से /Revenue By : Shri Sanjib Banerjee, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 25/02/2026 घोषणा की तारीख/Date Of Pronouncement : 25/02/2026

For Appellant: Shri P.K.Mishra, AdvocateFor Respondent: Shri Sanjib Banerjee, Sr. DR
Section 148Section 148ASection 151

order as well as the notice are issued on 22 April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151 (ii) of the Act. The proviso to Section 151 of the Act has been ... order as well as the notice are issued on 7th April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section 151 (ii) of the Act. The provisio to Section 151 has been inserted only with

Sudarsanam Bhaskaran, Chennai vs. ITO, Ncw-10(3), Chennai

The appeal of the assessee is allowed

ITA 3657/CHNY/2025[2018-19]Status: DisposedITAT Chennai25 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3657/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19

For Appellant: Mr. S. Girish Kumar, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 147Section 148Section 148ASection 151Section 250

notice u/s.148 of the Act came to be issued on 19.04.2022 for the A.Y. 2018-19. 41. The provisions of Section 151 defines the sanctioning authority and the relevant provisions as it stood at that point in time reads as under: “151. Specified authority for the purposes of section

Shailesh Asalraj Jain, Mumbai vs. Principal Commissioner of Income Tax, Mumbai 20, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2559/MUM/2025[2018-2019]Status: DisposedITAT Mumbai24 Feb 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19

For Appellant: Mr. Devendra JainFor Respondent: 03/12/2025
Section 147Section 148ASection 263

both have been issued beyond a period of three years. 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided Therefore, the sanctioning authority has to be the PCCIT as provided Therefore, the sanctioning authority

Ashaben Babulal Gala, Mumbai vs. ITO 41(4)(1), Mumbai

In the result, the Assessee's appeal is allowed on legal aspect

ITA 8633/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Feb 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2017-18 Ashabenbabulal Gala, National Faceless Centre, C-536, Panbai Nagar, Nfac, New Delhi, Shreeprastha 2Ndroad, Near Ito – 41(4)(1), Vs. Viva Super Market, Kautilyabhavan, Mumbai. Nalasopara (West), Umrale, Palghar, Maharashtra - 401203. (Appellant) (Respondent) Pan: Afzpg 0653 H Present For: Assessee By : Shri. Vikrant Vora Revenue By : Shri. Surendra Mohan, (Sr.D.R) Date Of Hearing : 23.02.2026 Date Of Pronouncement : 23.02.2026 O R D E R Per :Narender Kumar Choudhry:

For Appellant: Shri. Vikrant VoraFor Respondent: Shri. Surendra Mohan, (SR.D.R)
Section 250

approval from the Range Head i.e., Range-26(1), Mumbai and Principal Commissioner of Income Tax {Pr. CIT} – 17, Mumbai but not from the Sanctioning Authority i.e. Pr. CCIT, as prescribed in Section 151(ii) of the Act, and therefore violated such provisions of law, which would entail quashing ... order as well as the notice are issued on 7th April, 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCIT as provided under Section 151 (ii) of the Act. The proviso to Section 151 has been inserted only with

M/S.Wellknown Polyesters Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 4(3)(1), Mumbai

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

ITA 8704/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 147Section 148Section 148ASection 151

Court in the case of Union of India v. Rajeev Bansal, reported in [2024] 469 ITR 46, wherein it has been held that the sanctioning authority has to be in accordance with the provisions of section 151 of the Act, based on the new provisions u/s 148A

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

case of approval. The learned Counsel for the assessee has submitted that in the case of the assessee neither the Assessing Officer nor the sanctioning authority has given any specific reasons for coming to the conclusion that it was a fit case for issuing notice ... would by no means suffice the statutory requirement as contemplated in Sec. 151 of the Act, ie, satisfaction on the part of the sanctioning authority, on the reasons recorded by the A.O, that it is a fit case for issuance of a notice u/s 148 of the Act. As provided

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

case of approval. The learned Counsel for the assessee has submitted that in the case of the assessee neither the Assessing Officer nor the sanctioning authority has given any specific reasons for coming to the conclusion that it was a fit case for issuing notice ... would by no means suffice the statutory requirement as contemplated in Sec. 151 of the Act, ie, satisfaction on the part of the sanctioning authority, on the reasons recorded by the A.O, that it is a fit case for issuance of a notice u/s 148 of the Act. As provided

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

In the result, all the six appeals i

ITA 1873/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

case of approval. The learned Counsel for the assessee has submitted that in the case of the assessee neither the Assessing Officer nor the sanctioning authority has given any specific reasons for coming to the conclusion that it was a fit case for issuing notice ... would by no means suffice the statutory requirement as contemplated in Sec. 151 of the Act, ie, satisfaction on the part of the sanctioning authority, on the reasons recorded by the A.O, that it is a fit case for issuance of a notice u/s 148 of the Act. As provided