“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

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

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

Imran Majeed, Srinagar vs. ITO Ward 1, Srinagar

In the result, the appeal for the Asstt

ITA 585/ASR/2024[2018-19]Status: DisposedITAT Amritsar25 Nov 2025AY 2018-19

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

Shambhu Dayal Soni, Ramganj Bazar vs. Income Tax Officer Ward 2(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 921/JPR/2025[2017-18]Status: DisposedITAT Jaipur20 Nov 2025AY 2017-18

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT

Section 115BSection 147Section 148Section 148ASection 149(1)(b)Section 151(2)Section 69A

three years from the end of the relevant assessment year, i.e. 2017-18. In such cases, sanction was required u/s 151(2), where the sanctioning authority is Principal Chief Commissioner of Income Tax or Pr. Director General of Income Tax. The relevant provisions are quoted below as these stood ... three years from the end of the relevant assessment year, i.e. 2017-18. In such cases, sanction was required u/s 151(2), where the sanctioning authority is Principal Chief Commissioner of Income Tax or Pr. Director General of Income Tax. The relevant provisions are quoted below as these stood

Sonu Agarwal, Jaipur vs. Income Tax Officer Ward 1(3), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1263/JPR/2025[2016-2017]Status: DisposedITAT Jaipur19 Nov 2025AY 2016-2017

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Gaurav Awasthi, JCIT

Section 10(38)Section 139Section 147Section 148Section 148ASection 250

issued on 02.07.2022, beyond the period of 3 years, which were elapsed on 31.03.2020. Accordingly, as per provisions of section 151(ii) the sanctioning authority under the new regime are Principal Chief Commissioner or Principal Director General or Where there is no Principal Chief Commissioner or Principal Director General, Chief ... letter F.No. Pr. CIT- 1/RPR/Tech/2022-23 dated 28.06.2022. The aforesaid facts are on records and are not disputed by the revenue. Since, the issue of sanctioning authority is no more res integra, as has been specifically deliberated upon and guided by the Hon'ble Apex Court in the case of Rajeev

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

Since the reopening in the instant case has been made beyond 3 years from the end of the relevant assessment year, the specified sanctioning authority for the purposes of section 148 of the Act is Learned PCCIT. Since the approval in the instant case has been obtained from a wrong

Ratan N Motwani (HUF), Mumbai vs. ITO Ward 23(3)(1), Mumbai

In the result, assessee’s appeal is allowed

ITA 5532/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18

Bench: Smt. Beena Pillai & Smt.Renu Jauhri7 (A.Y.2017-18)

For Appellant: Shri. Bhadresh Doshi, CAFor Respondent: Shri Uma Shankar Prasad- CIT

Section 132Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 68

orders of lower authorities and has made a detailed written submission on 11.11.2025. Relevant portion of the submission pertaining to the validity of sanctioning authority u/s. 151 is reproduced below wherein ld. DR has discussed the relevant judgments: “1. Summary of Ramesh Bachulal Mehta case (Supra ... more than three years have elapsed from the end of the relevant assessment year.]” Thus, in view of the legal provisions, clearly the sanctioning authority in this case is the Pr. CCIT/CCIT and not the Pr. CIT as more than three years have elapsed from the end of the assessment

Konda Karabi, Jamshedpur vs. DCIT, Circle-1, Jamshedpur

In the result, the grounds of appeal raised by the assessee are allowed for statistical for statistical purposes

ITA 4/RAN/2025[2018-19]Status: DisposedITAT Ranchi12 Nov 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahaykonda Karabi, D.C.I.T., G/15, Nargis, Ashiana Garden Sonari, Circle-1, Vs. Jamshedpur-831011 Jamshedpur. Pan No. Abwpk 3757 F Appellant/ Assessee Respondent/ Revenue

Section 143(3)Section 144BSection 147Section 148Section 148ASection 151Section 151A

order as passed is void ab-initio, bad in law and fit to set aside. 5. For that the sanctioning authority has not applied his judicial mind before according sanction u/s 151. The approval has been granted for reopening of the assessment in a mechanical manner and without due application

Income Tax Officer 17(1)(1), Mumbai vs. Ashok Amritlal Nayak, Mumbai

In the result, appeal of the revenue is dismissed and the C

ITA 3484/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Surendra Mohan, Sr. DRFor Respondent: Shri Rahul Hakani, AR

Section 115BSection 143(1)Section 148Section 151ASection 250Section 68

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

Lumar Gems, Mumbai vs. ACIT Circle 23(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 3450/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Respondent: Shri Surendra Mohan, Sr. DR

Section 147Section 148Section 148ASection 151Section 250Section 68Section 69C

Paresh Hiralal Shah, Mumbai vs. Income Tax Officer Ward 34(3)(2), Mumbai

In the result, the CO filed by the Assessee is allowed, whereas the appeal filed by the Revenue stands dismissed

ITA 4775/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhryassessment Year: 2018-19 Mr. Paresh Hiralal Shah, Income Tax Officer, 302, Shree Krishna Sadan, Ward 34(3)(2), Paranjpe Scheme No.2, (Assessment Unit Subhash Road, Vile Parle East, Vs. Income Tax Department) Mumbai – 400 057 Kautilya Bhavan, Pan: Albps7761C Bandra Kurla Complex, Bandra (East), Maharashtra - 400051 (Appellant) (Respondent) Present For: Assessee By : Shri Shashi Bekal, Ld. A.R. Revenue By : Shri Vikas Chandra, Ld. Sr. D.R. Date Of Hearing : 10.11.2025 Date Of Pronouncement : 10.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 20.06.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2018-19. 2. In The Instant Case, Though The Notice U/S 148A(D) Of The Act Was Issued Within 3 Years From The End Of The Relevant Assessment Year, However, It Is Admitted That The Notice U/S 148 Of The Act Was 2 Mr. Paresh Hiralal Shah

For Appellant: Shri Shashi Bekal, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R

Section 147Section 148Section 148ASection 151Section 250

Argos Holdings Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, Circle Int Tax 1(1)(1), Delhi

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

ITA 3633/DEL/2025[2017-18]Status: DisposedITAT Delhi06 Nov 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR

Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

initio. To elaborate, the sanction recorded u/s 151 of the Act cannot be done without any file-note or separate order documenting the sanctioning authority’s satisfaction under Section 147 read with Section 6(3). Thus, the A.O.’s finding that Argos is a “shell entity” stems from a reproduction

Argos Holdings Pte. Ltd., Singapore vs. Deputy Commissioner of Income Tax, Circle Int Tax 1(1)(1), Delhi

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

ITA 3632/DEL/2025[2015-16]Status: DisposedITAT Delhi06 Nov 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri S.K. Tulsiyan, AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR

Section 144C(5)Section 147Section 148Section 148ASection 151Section 194LSection 1ISection 260Section 6(3)Section 6(3)(ii)

State Bank of India, Mumbai vs. The Assistant Commissioner of Income Tax – 2(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1377/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Nov 2025AY 2018-19

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

For Appellant: Shri Ninad PatadeFor Respondent: Shri. Arun Kanti Datta- CIT DR

Section 143(3)Section 147Section 148Section 148ASection 151Section 250Section 37(1)Section 40

Paras Palaza Private Limited, Bangaluru vs. Income Tax Officer, Ward 10(4), Kolkata, Govt Place

In the result, the appeal of the assessee is allowed

ITA 2676/KOL/2024[2012-13]Status: DisposedITAT Kolkata03 Nov 2025AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Paras Plaza Pvt. Ltd. Income Tax Officer, No.5, Mel Layout, Bagalagunte, Ward 10(4), Kolkata Vs. Bangalore, Karnataka-560088 3, Govt Place, Kolkata-700001 (Respondent) (Appellant) Pan No. Aaecp8301N Assessee By : Shri Amit Agarwal, Ar Revenue By : Shri Manoj Kumar Pati, Dr Date Of Hearing: 10.09.2025 Date Of Pronouncement: 03.11.2025

For Appellant: Shri Amit Agarwal, ARFor Respondent: Shri Manoj Kumar Pati, DR

Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 151

dated 28.12.2019 on the ground that the notice u/s 148 of the Act on 26.03.2019 was issued even before the mandatory approval of the sanctioning authority was received i.e. PCIT-4, Kolkata, approval u/s 151 of the Act. “IV. The impugned reassessment order dated 28th December, 2019 passed

ACIT(It)-1(2)(1), Mumbai vs. Barclays Execution Services Limited, London

In the result, the appeal filed by the Revenue is dismissed and the cross-objection filed by the assessee is dismissed as infructuous

ITA 4253/MUM/2025[2017]Status: DisposedITAT Mumbai31 Oct 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 144CSection 147Section 148Section 148ASection 151

been held that where more than three years had expired from 12 Barclays Execution Services Limited end of assessment year 2018-19, sanctioning authority under section 151(ii) should have been the Principal Chief Commissioner and not the Principal Commissioner, and thus, the order under section 148A(d) and notice ... Principal Commissioner were to be quashed and set aside. “where more than three years had expired from end of assessment year 2018-19, sanctioning authority under section 151(ii) should have been Principal Chief Commissioner and not Principal Commissioner and, thus, order under section 148A(d) and notice under section

Satinder Paul Through L/H Neelam Saini, Pinjore vs. Income Tax Officer, Panchkula

In the result, the ground no

ITA 136/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh30 Oct 2025AY 2017-18

Bench: SH. SANJAY GARG (Judicial Member)

For Appellant: Smt. Neelam Dhiman, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr.DR

Section 10Section 10(10)Section 143(1)

submit their VRS/VSS applications in the prescribed format In triplicate indicating clearly the Scheme under which they opt for VRS/VSS, to the Sanctioning Authority through proper channel. The Sanctioning Authority will communicate the acceptance of VRS/VSS to the employee indicating the date of relieving based on the decision

Amit Suresh Agrawal, Satara vs. ITO Ward-2, Satara

In the result, appeal of the assessee is partly allowed

ITA 2225/PUN/2025[2016-17]Status: DisposedITAT Pune30 Oct 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2225/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Amit Suresh Agrawal, V The Income Tax Officer, Amit Trading Co, Plot No.35, S Ward-2, Satara. Satara – 415002. Maharashtra. Pan: Abgpa2925D Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Kulkarni – Advocate Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This 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.2016-17 Dated 02.04.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated 10.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 149(1)(b)Section 151Section 151ASection 153ASection 153CSection 250Section 271(1)(c)Section 68

Siddharth Raikumar Nahar, Pune vs. DCIT, Cir-5, Pune

In the result, the appeal filed by the assessee is allowed as per terms indicated above

ITA 2062/PUN/2025[2017-18]Status: DisposedITAT Pune29 Oct 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2062/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Bharat Andhale

Section 147Section 148Section 148ASection 151Section 69A

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(ii) of the Act should be the Principal Chief Commissioner of Income Tax ("PCCIT") and not the PCIT. Mr. Gandhi says ... order as well as the notice are issued on 22nd April 2022, both have been issued beyond a period of three years. Therefore, the sanctioning authority has to be the PCCIT as provided under Section151(ii) of the Act. The proviso to Section 151 of the Act has been inserted

Wudstay Travels Private Limited, Gurgaon vs. Assistant Commissioner of Income Tax Circle 25(1), New Delhi

In the result the appeal of the assessee is allowed

ITA 2996/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Oct 2025AY 2017-18

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2017-18 Wudstay Travels Private Vs. Assistant Commissioner Limited D8/4 First Floor, Of Income Tax Circle 25 (1) Exclusive Floors Dlf Phase New Delhi -5 Gurgaon Dlf Qe So Gurgaon Pan No. Aabcw6379A (Appellant) (Respondent)

Section 142(1)Section 144Section 147Section 148Section 148ASection 194CSection 69

notice /order was issued on 21-07-2022 after a period of three years from the end of 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 ... Ward -3(3)(1) the Co-ordinate bench held that where three years had expired from the end of the Assessment year 2018-19, sanctioning authority u/s 151(ii) of the Act should have been Principal Chief Commissioner and not Principal Commissioner, thus order under section 148A(d) and notice

Deputy Commissioner of Income Tax, Jalgaon vs. Taradevi Ratanlal Bafna, Jalgaon

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

ITA 499/PUN/2025[2018-19]Status: DisposedITAT Pune24 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19

For Appellant: S/Shri Suchek Anchaliya and Tushar NagoriFor Respondent: Shri Amit Bobde, CIT

Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 148ASection 68Section 69C

relevant assessment year. He submitted that since 148 notice is dated 07.04.2022 and the assessment year involved is assessment year 2018-19, therefore, the sanctioning authority is Principal Chief Commissioner of Income Tax or Principal Director General or Chief Commissioner of Income Tax or Director General of Income Tax. However ... 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 proviso to Section 151 has been inserted only with

Income Tax Officer Ward 2(2) Kalyan, Kalyan vs. Samrat Madhav Paikrao, Shahpur

In the result, appeal of the revenue is dismissed and cross- objection filed by the assessee is allowed

ITA 4759/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Oct 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Shriram Bajaj, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R

Section 148Section 148ASection 151

order as well as the notice are issued on 7" 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 (i) of the Act. The proviso to Section 151 has been inserted only with