← All Phrases

“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

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, both appeals of the assessee are allowed

ITA 5113/DEL/2025[2016-17]Status: DisposedITAT Delhi24 Dec 2025AY 2016-17

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

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 68

regime from 1st April, 2021 and in the compliance of the Hon’ble Supreme Court order in the case of Ashish Aggarwal (supra), the sanctioning Authorities should have been Pr. Chief Commissioner or Pr. Director General or the Chief Commissioner but in this case the approval has been obtained from ... notice/order was issued on 28- 07-2022 after a period of three years from the end of o relevant assessment Year, the sanctioning authority should have been Principal Chief Commissioner or Principal Director General or Chief commissioner but in this case the approval has been obtained from the Pr. Commissioner

DCIT, Central Circle-20, Delhi vs. Lotus Herbals Pvt. Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

section 151(1) is granted." The aforesaid could not be regarded as valid satisfaction inasmuch the aforesaid note: (a) clearly indicate that the sanctioning authority simply perused the reasons, with looking into the records; and (b) does not show any application of mind which, it is submitted, is sine ... which only leads to the inescapable conclusion that there was, in reality, no perusal of assessment record and independent application of mind by the sanctioning authority (les) for according approval. The Orissa High Court in the case of ACTT vs. Serajuddin & Co. (2023) 454 ITR 312 (Ori), while disapproving

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

section 151(1) is granted." The aforesaid could not be regarded as valid satisfaction inasmuch the aforesaid note: (a) clearly indicate that the sanctioning authority simply perused the reasons, with looking into the records; and (b) does not show any application of mind which, it is submitted, is sine ... which only leads to the inescapable conclusion that there was, in reality, no perusal of assessment record and independent application of mind by the sanctioning authority (les) for according approval. The Orissa High Court in the case of ACTT vs. Serajuddin & Co. (2023) 454 ITR 312 (Ori), while disapproving

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

section 151(1) is granted." The aforesaid could not be regarded as valid satisfaction inasmuch the aforesaid note: (a) clearly indicate that the sanctioning authority simply perused the reasons, with looking into the records; and (b) does not show any application of mind which, it is submitted, is sine ... which only leads to the inescapable conclusion that there was, in reality, no perusal of assessment record and independent application of mind by the sanctioning authority (les) for according approval. The Orissa High Court in the case of ACTT vs. Serajuddin & Co. (2023) 454 ITR 312 (Ori), while disapproving

DCIT, CC-20, Delhi vs. Lotus Herbals Pvt. Ltd., Delhi

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

section 151(1) is granted." The aforesaid could not be regarded as valid satisfaction inasmuch the aforesaid note: (a) clearly indicate that the sanctioning authority simply perused the reasons, with looking into the records; and (b) does not show any application of mind which, it is submitted, is sine ... which only leads to the inescapable conclusion that there was, in reality, no perusal of assessment record and independent application of mind by the sanctioning authority (les) for according approval. The Orissa High Court in the case of ACTT vs. Serajuddin & Co. (2023) 454 ITR 312 (Ori), while disapproving

DCIT, Central Circle-20, New Delhi vs. Lotus Herbals P.Ltd, Delhi

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

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

section 151(1) is granted." The aforesaid could not be regarded as valid satisfaction inasmuch the aforesaid note: (a) clearly indicate that the sanctioning authority simply perused the reasons, with looking into the records; and (b) does not show any application of mind which, it is submitted, is sine ... which only leads to the inescapable conclusion that there was, in reality, no perusal of assessment record and independent application of mind by the sanctioning authority (les) for according approval. The Orissa High Court in the case of ACTT vs. Serajuddin & Co. (2023) 454 ITR 312 (Ori), while disapproving

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

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

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

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

Trishul Homes & Infrastructure Private Limited, Delhi vs. DCIT, Central Circle-31, Delhi

In the result, both these appeals are allowed

ITA 502/DEL/2025[2017-18]Status: DisposedITAT Delhi16 Dec 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Ble & Shri Sanjay Awasthiआ.अ.सं/.I.T.A Nos.501 & 502/Del/2025 िनधा"रणवष"/Assessment Years:2015-16 & 2017-18 बनाम Trishul Homes & Infrastructure Dcit, Private Limited, Vs. Central Circle-31, Delhi. 101-102, 3 Tolstoy Marg, Connaught Place, New Delhi. Pan No.Aaect5592R अपीलाथ" Appellant ""यथ"/Respondent

Section 144BSection 153ASection 153BSection 153DSection 250

subject. 2.1 The Ld. DR mentioned that the approval had been obtained as per law and it is not necessary for the sanctioning authority to mandatorily examine the seized material etc. over a period of several days before granting approval. The Ld. DR relied on the orders of the authorities ... very carefully considered one and such careful consideration has to be visible from the paper trail between an AO and the sanctioning authority. In this case, not only is the approval given on the same date but it is also given in a bunched-up manner. Respectfully, following

Trishul Homes & Infrastructure Private Limited, Delhi vs. DCIT, Central Circle-31, Delhi

In the result, both these appeals are allowed

ITA 501/DEL/2025[2015-16]Status: DisposedITAT Delhi16 Dec 2025AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri Sanjay Awasthiआ.अ.सं/.I.T.A Nos.501 & 502/Del/2025 िनधा"रणवष"/Assessment Years:2015-16 & 2017-18 बनाम Trishul Homes & Infrastructure Dcit, Private Limited, Vs. Central Circle-31, Delhi. 101-102, 3 Tolstoy Marg, Connaught Place, New Delhi. Pan No.Aaect5592R अपीलाथ" Appellant ""यथ"/Respondent

Section 144BSection 153ASection 153BSection 153DSection 250

subject. 2.1 The Ld. DR mentioned that the approval had been obtained as per law and it is not necessary for the sanctioning authority to mandatorily examine the seized material etc. over a period of several days before granting approval. The Ld. DR relied on the orders of the authorities ... very carefully considered one and such careful consideration has to be visible from the paper trail between an AO and the sanctioning authority. In this case, not only is the approval given on the same date but it is also given in a bunched-up manner. Respectfully, following

Rajendra Sahu, Katni vs. Income Tax Officer-1, Katni

ITA 163/JAB/2023[2014-15]Status: DisposedITAT Jabalpur12 Dec 2025AY 2014-15

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rahul Bardia, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR 1
Section 131Section 147Section 148Section 69

case in sustaining the order, when notice issued u/s 148 is defective. There is no application of mind of Ld AO and also of sanctioning authority. (3) The Ld CIT (A) erred in law and facts of the case in sustaining the order, when assessee made specific request to share

Income Tax Officer, Ward 46(1), New Delhi vs. Mam Raj Chunni Lal Exim, New Delhi

In the result the appeal of the Revenue is dismissed and the cross objection of the assessee is partly allowed

ITA 3573/DEL/2024[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2016-17 Income Tax Officer, Vs Mam Raj Chunni Lal Exim Ward- 46 (1) Shop No. 5183, Ground New Delhi Floor, Lahori Gate, Naya Bazar, Delhi -110006 Pan No.Aaxfm0533B (Appellant) (Respondent)

Section 133ASection 147Section 148Section 148ASection 149(1)Section 151Section 151A

issued on 19-07-2022 after a period of three years from the end of relevant Assessment Year, the sanctioning authority as per the section 151(ii) of the Act should have been Principal Chief Commissioner or Principal Director General or Chief commissioner but in this case the 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

introduction of new regime which has 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

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

liable to be quashed. 4. That the approval granted under Section 151 of the Act is mechanical and without independent satisfaction of the sanctioning authority, vitiating the reassessment proceedings. The Commissioner of Income Tax (Appeals) has 6 erred in failing to appreciate this defect and in upholding the reassessment order ... jurisdictionally defective. The record reveals that the proposal was put up by the Assessing Officer, and while the column requiring “satisfaction of the sanctioning authority” is filled, it is only with a mechanical endorsement by the Principal Commissioner of Income Tax. There is no independent recording of reasons

Shankeshwar Exim LLP, Mumbai vs. ITO - 19(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 5117/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Dec 2025AY 2018-19

Bench: Smt. Beena Pillai, Jm & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 148Section 250Section 69C

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

Rajendra Sahu, Katni vs. Income Tax Officer-1, Katni

ITA 162/JAB/2023[2013-14]Status: DisposedITAT Jabalpur28 Nov 2025AY 2013-14

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2013-14 Rajendra Sahu, Vs. Income Tax Officer-1, Ram Manohar Lohiya Ward No. 4, Behind Katni Durga Hospital, Adarsh Colony, Katni Pan: Auvps4330A (Appellant) (Respondent) Assessee By: Sh. Rahul Bardia, C.A. Revenue By: Sh. N.M. Prasad, Sr. Dr 1 Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 20.10.2023 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Orders Passed By The Assessing Officer Under Section 147 R.W.S. 144B Of The Income Tax Act On 27.03.2022. The Grounds Of Appeal Are As Under:- “(1) The Order Passed By The Ld Cit (A) Is Bad In Law & Facts, Void Ab Initio & Without Jurisdiction. (2) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When Notice Issued U/S 148 Is Defective. There Is No Application Of Mind Of Ld Ao & Also Of Sanctioning Authority. (3) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When Assessee Made Specific Request To Share Copies Of All The Statement Recorded By The Investigation Wing Regarding The Sale Of Properties. These Copies Were Not Given Inspite Of Using Them Against The Assessee. (4) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When The Hon'Ble Tribunal For Benami Transactions Has Released The Property & Given Relief To Alleged Benamidar & Alleged Beneficial Owner. Copy Of Order Was Filed On Record. (5) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Addition Of Rs 88,52,740/-U/S 69. 1 A.Y. 2013-14 Rajendra Sahu (6) The Appellant Reserves The Right To Add, Amend Or Alter Any Grounds Of Appeal.”

For Appellant: Sh. Rahul Bardia, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR 1
Section 131Section 147Section 148Section 69

case in sustaining the order, when notice issued u/s 148 is defective. There is no application of mind of Ld AO and also of sanctioning authority. (3) The Ld CIT (A) erred in law and facts of the case in sustaining the order, when assessee made specific request to share

Archana Muralidhar Bhandwalkar, Pune vs. Income Tax Officer Ward 5(2), Pune

In the result, appeal of the assessee is partly allowed

ITA 1840/PUN/2025[2016-17]Status: DisposedITAT Pune28 Nov 2025AY 2016-17
Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 271(1)(c)Section 56(2)(vii)Section 69A

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

Archana Muralidhar Bhandwalkar, Pune vs. Income Tax Officer, Ward 5(2), Pune

In the result, appeal of the assessee is partly allowed

ITA 1615/PUN/2025[2016-17]Status: DisposedITAT Pune28 Nov 2025AY 2016-17

Bench: DR. DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 14Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 271(1)(c)Section 56(2)(vii)

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

Mr Ramsoch Dashrath Yadav, Pune vs. ITO, Ward-8(3), Pune

In the result, appeal of the assessee is partly allowed

ITA 2034/PUN/2025[2018-19]Status: DisposedITAT Pune27 Nov 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2034/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Mr.Ramsoch Dashrath Yadav, V 1.The Income Tax Officer, Tayappa Chawl, Near Urdu S Ward-8(2), Pune. School, Kharalwadi, Pimpri, Pune – 411018. 2.Assistant/Dy.Commission Er Of Income Tax/Income Tax Officer, National Faceless Assessment Centre, Delhi. Pan: Acypy0615P Appellant/ Assessee Respondent / Revenue Assessee By Dr.Prashant Munot Revenue By Shri Ambarnath Khule-Jcit(Through Virtual Hearing) Date Of Hearing 26/11/2025 Date Of Pronouncement 27/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2018-19 Dated 30.06.2025 Emanating From The Assessment Order Passed Under

Section 131(1)Section 147Section 148Section 148ASection 250

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

Imran Majeed, Srinagar vs. ITO, Ward 1, Srinagar

In the result, the appeal for the Asstt

ITA 586/ASR/2024[2019-20]Status: DisposedITAT Amritsar25 Nov 2025AY 2019-20

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 147Section 148Section 148ASection 151Section 151ASection 250

that in the instant case, more than three years has expired from the end of the assessment year 2018-19, and the sanctioning authority u/s 151(ii) of the Act 61, (as per amended finance Act 2022 ) should have been “ Principal Chief Commissioner of Income Tax” (and not the Principal ... that the Assessment Year ("AY") is 2018-19 and, therefore, since more than three years have expired from the end of the assessment year, Sanctioning Authority under Section 151(i) of the Act should be the Principal Chief Commissioner of Income Tax ("PCCIT") and not the PCIT. Mr. Gandhi says