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“specified authority”

ReassessmentSection 151Section 1511,163 judgments

The decision most relied on for specified authority is (P.) Ltd. v. ITO (221 ITR 538), cited in 125 judgments on BharatTax.

Leading authorities on specified authority

(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.

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.

CIT v. Mahendra C. Shah
299 ITR 305 · 2008 · High Court
80
citing judgments

During a search operation, the authorized officer recording a statement under Section 132(4) must fully explain Explanation 5 to Section 271(1)(c) to the assessee, particularly the requirement to specify the manner of earning undisclosed income, for a valid claim of penalty immunity. Income not declared or advance tax not paid proportionately before the search date is treated as undisclosed, thereby disallowing advance tax benefits.

Bar Association v. State of U P
6 SCC 267 · 2024 · Supreme Court
70
citing judgments

The Supreme Court, when exercising its jurisdiction under Article 142 of the Constitution, is not bound by the procedural requirements of law. This power allows the Court to issue directions that may modify or waive certain procedural mandates, such as those related to reassessment notices.

Dass Khanna v. ITO
460 ITR 546 · 2024 · High Court
41
citing judgments

The authority required to grant prior approval under Section 151 of the Income-tax Act for reassessment proceedings varies based on the applicable time limit for reassessment, as limitation is inextricably intertwined with the rank of the specified approving authority.

Infrastructure Pvt. Ltd. v. ITO
463 ITR 702 · 2024 · High Court
32
citing judgments

The validity of sanction for issuing orders under section 148A(d) and notices under section 148 must be tested with reference to the amended section 151. If sanction is not granted by an authority specified under section 151(ii), such orders and notices are invalid and liable to be quashed.

Vikas Gupta v. Union of India
142 Taxmann.com 253 · 2022 · High Court
27
citing judgments

The signing of a notice or document by the specified authority is a mandatory requirement under section 282A(1) of the Income Tax Act, 1961, and cannot be treated as an empty formality. Approval under section 151 requires the signature, name, and designation of the specified authority.

Judgments citing specified authority

Radhe Developers, Rajkot vs. The Deputy Commissioner of Income Tax, Central -1, Rajkot

ITA 550/RJT/2024[2018-19]Status: DisposedITAT Rajkot10 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 549 & 550/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 (Hybrid Hearing) Radhe Developers Vs The Deputy Commissioner Of Income Tax, Central-1 . Office No. 47, Ankur Commercial Center, Opp. Income Tax Office, Amruta Swaminarayan Gurukul, Estate Building, Near Girnar Gondal Road, Rajkot Cinema, M G Road, Rajkot Rajkot-360001 Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatfr3387E (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147

been issued on 19/11/2022 to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148, the assessee has filed an income tax return on 23/11/2022, declaring

Radhe Developers, Rajkot vs. The Deputy Commissioner of Income Tax, Central-1, Rajkot

ITA 549/RJT/2024[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 549 & 550/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 (Hybrid Hearing) Radhe Developers Vs The Deputy Commissioner Of Income Tax, Central-1 . Office No. 47, Ankur Commercial Center, Opp. Income Tax Office, Amruta Swaminarayan Gurukul, Estate Building, Near Girnar Gondal Road, Rajkot Cinema, M G Road, Rajkot Rajkot-360001 Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatfr3387E (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147

been issued on 19/11/2022 to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148, the assessee has filed an income tax return on 23/11/2022, declaring

DCIT, Central Circle 1, Rajkot vs. Shri Jagjivan Ranchhodbhai Sakhiya, Rajkot

In the result, both the appeals of the revenue, are dismissed

ITA 744/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

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

For Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 151Section 69C

been issued on 25-08-2022 to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148, the assessee has filed an Income tax return

DCIT, Central Circle 1, Rajkot vs. Jagjivan Ranchhodbhai Sakhiya, Rajkot

In the result, both the appeals of the revenue, are dismissed

ITA 743/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

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

For Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 151Section 69C

been issued on 25-08-2022 to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148, the assessee has filed an Income tax return

DCIT, Central Circle 1, Rajkot vs. Buildcon Associates, Rajkot

ITA 691/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

been issued on 23-03-2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an Income

DCIT, Central Circle 1, Rajkot vs. Krishna Developers, Rajkot

ITA 688/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

been issued on 25/08/2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an income tax return

DCIT, Central Circle 1, Rajkot vs. Buildcon Associates, Rajkot

ITA 675/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

been issued on 23-03-2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an Income

DCIT, Central Circle -1, Rajkot vs. Buildcon Associates, Rajkot

ITA 674/RJT/2024[2015-16]Status: DisposedITAT Rajkot09 Mar 2026AY 2015-16

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

been issued on 23-03-2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an Income

Krishna Developers, Rajkot vs. Deputy Commissioner of Income Tax, Central 1, Rajkot

ITA 544/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

been issued on 25/08/2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an income tax return

Krishna Developers, Rajkot vs. The Deputy Commissioner of Income Tax, Central-1, Rajkot

ITA 543/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

been issued on 25/08/2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an income tax return

Buildcon Associates, Rajkot vs. Deputy Commissioner of Income Tax, Central - 1, Rajkot

ITA 508/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

been issued on 23-03-2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an Income

Buildcon Associates, Rajkot vs. Deputy Commissioner of Income Tax, Central - 1, Rajkot

ITA 507/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

been issued on 23-03-2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an Income

Buildcon Associates, Rajkot vs. Deputy Commissioner of Income Tax, Central -1, Rajkot

ITA 506/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

been issued on 23-03-2022, to the assessee after following due procedure as per the Act and with prior approval of the specified authority as per section 151 of the Act. In response to the notice issued under section 148 of the Act, the assessee has filed an Income

Kalpana Sanjay Pawar, Mumbai vs. ITO WD-41(1)(2), Mumbai

ITA 9047/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Mar 2026AY 2017-18

Bench: the Tribunal challenging the validity of the re-assessment proceedings raising, inter alia, the following grounds: "2. On the facts and circumstances of the case and in law, the learned Assessing Officer has erred in issuing the order under Section 148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-1, Mumbai which was not the correct 'specified authority' as per Section 151 who should have approved it when three years have already elapsed from the

For Appellant: Shri Aditya RamachandranFor Respondent: Ms. Deepika Arora
Section 1Section 144BSection 147Section 148Section 148ASection 151Section 151A

148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-1, Mumbai which was not the correct 'specified authority' as per Section 151 who should have approved it when three years have already elapsed from the end of the relevant assessment year ... under Section 151(i) of the Act or the Principal Chief Commissioner of Income Tax under Section 151(ii) of the Act is the Specified Authority for seeking necessary approval. 7. In our view, the above issue is no longer res-integra and stands settled by the judgment

Sudhir Damji Bharani, Mumbai vs. ITO WD-27(3)(1), Navi Mumbai

ITA 9046/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Mar 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Aditya RamachandranFor Respondent: Ms. Deepika Arora
Section 144BSection 147Section 148Section 148ASection 149Section 151

148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-27, Mumbai which was not the correct 'specified authority' as per Section 151 who should have approved it when three years have already elapsed from the end of the relevant assessment year ... under Section 151(i) of the Act or the Principal Chief Commissioner of Income Tax under Section 151(ii) of the Act is the Specified Authority for seeking necessary approval. 7. In our view, the above issue is no longer res-integra and stands settled by the judgment

ITO 19 1 5 Mumbai, Mumbai vs. Johratussharaf Syedna Mufaddal Saifuddin, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 9040/MUM/2025[AMRPS6217J]Status: DisposedITAT Mumbai09 Mar 2026

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2017-18 Ito – 19(1)(5) Vs. Johratussharf Syedna 502, Piramal Chembers Mufaddal Saifuddin Lalbaug, Mumbai – Saifee Mahal, Ag Bell 400012. Marg, Mumbai – 400006. Pan/Gir No. Amrps6217J (Applicant) (Respondent)

Section 147Section 148Section 148ASection 151Section 250

this stage, it would be relevant to refer to the provisions of section 151 of the Act, which prescribe the specified authority for granting sanction for issuance of notice under section 148.The Hon’ble Supreme Court, while dealing with the issue of approval of the specified authority, in the case

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

section 147 of the Act, on the ground that the mandatory approval required under section 151 of the Act was not obtained from the specified authority. 13. Section 151 of the Act prescribes the authority whose prior approval is required before issuing notice under section 148 or passing an order ... under section 148A(d). The relevant provision reads as under: “151. Sanction for issue of notice. Specified authority for the purposes of section 148 and section 148A shall be,— (i) Principal Commissioner or Principal Director or Commissioner or Director, if three years or less than three years have elapsed from

Jignesh Natverlal Patel (Represnted by Late Natverlal Nanubhai Patel), Mumbai vs. ITO Ward 24(3)(1), Mumbai

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

ITA 6769/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Mar 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawaljignesh Natverlal Patel Vs Ito Ward-24(3)(1), Mumbai (Represented By Late Piramal Chamber, Lalbaug, Natverlal Nanubhai Patel) Mumbai-400012 401 Adarsh Building, Rto Four Bunglows, Andheri (West), Mumbai-400053 Pan:Aaapp1767B Appellant Respondent

For Appellant: Shri Aditya RamchandranFor Respondent: Shri Sushil B. Shende (Sr DR)
Section 139(1)Section 147rSection 148Section 148ASection 149Section 151Section 151ASection 250

148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-20, Mumbai which was not the correct 'specified authority' as per Section 151 who should have approved it when three years have already elapsed from the end of the relevant assessment year ... Section 148A of the Act is initiated before expiry of three years from the end of the relevant assessment year, the specified authority who can grant sanction/approval is the Principal Commissioner or Principal Director General or Commissioner or Director of Income Tax. However, as per clause (ii), if more than

Pedaveeti Swathi, Hyderabad vs. ITO, Ward 9(1), Hyderabad

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

ITA 1785/HYD/2025[2016-17]Status: DisposedITAT Hyderabad04 Mar 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1785/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Pedaveeti Swathi, Vs. Income Tax Officer, Hyderabad. Ward-9(1), Pan: Fugps2126J Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri T. Chaitanya Kumar, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 26/02/2026 घोषणा की तारीख/Date Of 04/03/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 27/02/2024 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri T. Chaitanya KumarFor Respondent: Dr. Sachin Kumar, Sr.AR
Section 115BSection 142(1)Section 144BSection 147Section 148Section 148ASection 149Section 151ASection 69A

following the mandatory procedure laid down u/s 148A (a)-(d) before issuance of notice u/s 148. The approval and satisfaction required from the specified authority under the amended law were not properly obtained or recorded, rendering the reassessment invalid in law. 6. The assessment was completed ex-parte without ensuring

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

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 148A be,— Govindan Gnanavel :- 3 -: (i) Principal Commissioner or Principal Director or Commissioner or Director ... escaped assessment in the case of the assessee for the relevant assessment year and the Assessing Officer has obtained prior approval of the specified authority to issue such notice.” Thus, on the facts of the present case, the Show Cause Notice u/s.148A(b) of the Act was issued upon