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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

Dy. Commissioner of Income Tax, Central Circle 3, Delhi vs. Pankaj Goel, Delhi

ITA 4159/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Dy. Commissioner Of Vs. Sh. Pankaj Goel, Income Tax, 662/3A, Ghati Road, Central Circle-3, Anand Paravt, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) With C.O. No.236/Del/2025 [Arising Out Of Ita No.4159/Del/2025] Assessment Year: 2017-18 Sh. Pankaj Goel, Vs. Dy. Commissioner Of Income 662/3A, Ghati Road, Tax, Anand Paravt, Central Circle-3, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) Assessee By Ms. Mansi Jain, Adv. Sh. Siddharth Bajaj, Adv. Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 17.12.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.4159/Del/2025 Along With Assessee’S Cross Objection C.O. No. 236/Del/2025 For Assessment & C.O. No.236/Del/2025

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

order was issued with the approval of the Commissioner of Income Tax (Exemption) [CIT(E)] on an assumption that the CIT(E) was a specified authority under the provisions of Section 151 of the Act. 8. The AO issued a notice dated 29.07.2022 under Section 148 of the Act accompanied ... Principal Chief Commissioner or Principal Director General or where there is no such authority, by Chief Commissioner or Director General. The determination of the specified authority for grant of approval under Section 151 of the Act depends on whether the notice under Section 148 of the Act has been issued

Mr. Bipin Agarwal, Delhi vs. ACIT, Central Circle-2, Noida

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

ITA 2844/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Dec 2025AY 2019-20

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalmr. Bipin Agarwal, Asst. Cit, 1001-1006, 10Th Floor, Central Circle-Ii, Narain Manzil, 23, Vs. Noida. Barakhamba Road, New Delhi-110101. Pan-Aewpa2901C (Appellant) (Respondent) Appellant By Shri Rajiv Khandelwal, Ca & Shri Jaind Jaiswal, Adv. Respondent By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 18.11.2025 Date Of Pronouncement 17.12.2025

Section 132Section 132(4)Section 147Section 148

case, the case was reopened u/s 147 by issuing notice u/s 148 issued on 29/03/2023 after taking approval from Bipin Agarwal vs. ACIT the specified authority under the Income Tax Act 1961. As per AO, during the course of the assessment proceedings u/s 147, the assessee was given several opportunities

Ankita Badal Mittal, Mumbai vs. Ward 3(3)(1), Mumbai

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

ITA 5484/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Dec 2025AY 2017-18

Bench: Shri Sandeep Gosain

Section 147Section 148Section 149Section 151Section 250Section 68Section 69A

passed and/or 148 notice issued after the expiry of the period of three years from the end of the relevant assessment year, the specified authority for grant of approval under section 151 is the Principal Chief Commissioner or the Principal Director General or the Chief Commissioner or Director General ... passed and/or 148 notice is issued after the expiry of the period of three years from the end of the relevant assessment year, the specified authority for grant of of approval under section 151 is the Principal Chief the Principal Director General Commissioner or or the Chief Commissioner or Director

Katrapally Venumadhav, Warangal vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 1396/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 151Section 270ASection 282

same were issued in contravention to the provisions of section 151 of the Act in respect of issue of specified authority and hence the subsequent proceedings and the impugned assessment order dt.23-08-2023 are also bad-in-law and are liable to be quashed. 2. That on the facts and circumstances ... that the AO had wrongly assumed jurisdiction primarily on two grounds, viz., (i) that the AO had failed to obtain the approval of the specified authority as per section 151(ii) of the Act (as was then available on statute); and (ii) that the notices under section 148A

Katrapally Venumadhav, Warangal vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 1395/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 151Section 270ASection 282

same were issued in contravention to the provisions of section 151 of the Act in respect of issue of specified authority and hence the subsequent proceedings and the impugned assessment order dt.23-08-2023 are also bad-in-law and are liable to be quashed. 2. That on the facts and circumstances ... that the AO had wrongly assumed jurisdiction primarily on two grounds, viz., (i) that the AO had failed to obtain the approval of the specified authority as per section 151(ii) of the Act (as was then available on statute); and (ii) that the notices under section 148A

Selvaraj Arokia Sagaya Raj, Chennai vs. DCIT, Ncc-22(1), Chennai

In the result, the appeal of the assessee is allowed, and the stay application is dismissed as infructuous

ITA 3597/CHNY/2025[2018-19]Status: DisposedITAT Chennai12 Dec 2025AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3597/Chny/2025 & S.A No.118/Chny/2025 िनधा%रण वष% /Assessment Year: 2018-19 Selvaraj Arokia Sagaya Raj, The Dy. Commissioner Of Income 6/9 Ff1, Soundariya Apartments, Vs. Tax, Voc 2Nd Main Road, Non Corporate Circle-22(1), Kodambakkam, Tambaram, Chennai. Chennai – 600 024. Pan: Aeypa 8464Q

For Appellant: Mr. N.V.Krishnan, AdvocateFor Respondent: Ms. Babitha, JCIT
Section 147Section 148Section 148ASection 250

section 148. The Assessing Officer shall, before issuing any notice under section 148,- (a) conduct any enquiry, if required, with the prior approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment; (b) provide an opportunity of being heard ... whether or not it is a fit case to issue a notice under section 148, by passing an order, with the prior approval of specified authority, within one month from the end of the month in which the reply referred to in clause (c) is received by him, or where

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

148A(d) of the Act & Notice u/s 148 of the Act for A.Y. 2016-17 (both dated 19/07/2022) has rightly been taken from the specified authority as per clause (i) of Section 151 of the Income Tax Act i.e. Pr. Commissioner of Income Tax, Delhi-10, New Delhi ... Aggarwal. The assessee’s case falls under the ambit of para 6.2 (ii) of the instruction No1 and the approval was obtained from the specified authority as per the Clause (i) of section 151 of the Act i.e Pr. Commissioner of Income Tax , Delhi-10. She further submitted that

ACIT, Central Circle-II, Lucknow vs. Rakesh Kumar Pandey, Gonda U.P

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 460/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

department has provided copy of order sheet on 24.10.2025. In which reasons are not recorded while issuing notice u/s 148 and approval taken from specified authority were also not provided. Though the case was selected for income escaping assessment of assessee covered by sec. 132 and Assessing Officer while issuing ... income chargeable to tax escaping assessment for any assessment year in the case of the assessee. ] (N.A.) Explanation.—For the purposes of this section, specified authority means the specified authority referred to in section 151.] The above applicable provision was obligatory on the part of AO to record satisfaction with

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT (Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 351/LKW/2025[2018-19]Status: DisposedITAT Lucknow11 Dec 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

department has provided copy of order sheet on 24.10.2025. In which reasons are not recorded while issuing notice u/s 148 and approval taken from specified authority were also not provided. Though the case was selected for income escaping assessment of assessee covered by sec. 132 and Assessing Officer while issuing ... income chargeable to tax escaping assessment for any assessment year in the case of the assessee. ] (N.A.) Explanation.—For the purposes of this section, specified authority means the specified authority referred to in section 151.] The above applicable provision was obligatory on the part of AO to record satisfaction with

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT(Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as

ITA 350/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 40A(3)Section 69

department has provided copy of order sheet on 24.10.2025. In which reasons are not recorded while issuing notice u/s 148 and approval taken from specified authority were also not provided. Though the case was selected for income escaping assessment of assessee covered by sec. 132 and Assessing Officer while issuing ... income chargeable to tax escaping assessment for any assessment year in the case of the assessee, ] (N.A.) Explanation.—For the purposes of this section, specified authority means the specified authority referred to in section 151.] The above applicable provision was obligatory on the part of AO to record satisfaction with

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT (Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 349/LKW/2025[2016-17]Status: DisposedITAT Lucknow11 Dec 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

department has provided copy of order sheet on 24.10.2025. In which reasons are not recorded while issuing notice u/s 148 and approval taken from specified authority were also not provided. Though the case was selected for income escaping assessment of assessee covered by sec. 132 and Assessing Officer while issuing ... income chargeable to tax escaping assessment for any assessment year in the case of the assessee. ] (N.A.) Explanation.—For the purposes of this section, specified authority means the specified authority referred to in section 151.] The above applicable provision was obligatory on the part of AO to record satisfaction with

Venkata Rama Krishnam Raju Chintalapati, Hyderabad vs. DCIT., Circle 8(1), Hyderabad

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

ITA 143/HYD/2025[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Us:

For Appellant: Shri KA Sai Prasad, CAFor Respondent: Shri Waseem UR Rehman
Section 147Section 148Section 148ASection 151

validity of the jurisdiction assumed by the A.O. for initiating proceedings u/s. 147 of the Act, i.e., without obtaining the approval of the specified authority u/s. 151(ii) of the Act, we find substance in the same. Admittedly, the reassessment proceedings u/s. 147 of the Act had been revamped vide ... 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. Explanation 1.—For the purposes of this section and section 148A, the information with the Assessing Officer which suggests that

Income Tax Officer, Ward-1, Warangal vs. Shiva Kumar Thota, Warangal

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

ITA 996/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Mrs. U. Mini Chandran
Section 147Section 148Section 148ASection 43BSection 68

validity of the jurisdiction assumed by the A.O. for initiating proceedings u/s. 147 of the Act, i.e., without obtaining the approval of the specified authority u/s. 151(ii) of the Act, we find substance in the same. Admittedly, the reassessment proceedings u/s. 147 of the Act had been revamped vide ... 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. Explanation 1.—For the purposes of this section and section 148A, the information with the Assessing Officer which suggests that

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

Court clarified: “… if the time limit of four years from the end of the assessment year falls between 20.03.2020 and 31.03.2021, then the specified authority under Section 151(2) has time only till 31.03.2021 to grant approval. The time limit under Section 151 of the old regime therefore expires ... notice under section 148 of the Act can be issued for AY 2015-16 as the same is issued without prior approval of the specified authority under the new regime in view of the judgement rendered by Hon’ble Supreme Court in the case of ‘Union of India and Others

Aakanksha Gupta, Delhi vs. ITO Ward 69(1), New Delhi, Delhi

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

ITA 2763/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Dec 2025AY 2017-18

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2763/Del/2025 िनधा"रणवष"/Assessment Year: 2017-18 बनाम Aakanksha Gupta, Income Tax Officer, C/O Ca Vaibhav Goel, Vs. Ward 69(1), 78, Navyug Market, 1St Floor, New Delhi. Ghazaibad, Uttar Pradesh. Pan No.Amhpg9430D अपीलाथ" Appellant ""यथ"/Respondent

Section 143(2)Section 144BSection 147Section 148Section 149Section 250Section 54

circumstances of the case, Ld CIT(A) erred in sustaining there-assessment proceedings initiated based on mechanical approval by the specifiedauthority; That, the specified authority failed to take cognizance of- 2 - approval was sought u/s 147(b) of the Income Tax Act, 1961 which was not existing

Motiwala Auto Pvt. Ltd., Aurangabad vs. ITO, Ward1(1), Auranabad, Aurangabad

In the result, the appeal of the assessee is allowed

ITA 486/PUN/2025[2015-16]Status: DisposedITAT Pune09 Dec 2025AY 2015-16
For Appellant: Shri Shubham N. RathiFor Respondent: Shri Rajesh Haladkar
Section 142(1)Section 144Section 147Section 148Section 251(1)(a)

time limit of three years from the end of an assessment year falls between 20 March 2020 and 31 March 2021, then the specified authority under Section 151(i) has extended time till 30 June 2021 to grant approval; e. In the case of Section 151 of the old regime ... time limit of four years from the end of an assessment year falls between 20 March 2020 and 31 March 2021, then the specified authority under Section 151(2) has extended time till 31 March 2021 to grant approval; f. The directions in Ashish Agarwal (supra) will extend

Garima Mrityunjay Singh, Mumbai vs. ITO WD-19(1)(1), Mumbai

In the result, appeal filed by assessee stands allowed

ITA 6065/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Dec 2025AY 2017-18

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

Section 148Section 148ASection 151Section 151ASection 69A

148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-19, 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 ... power of the Revenue to reopen assessments. The provision imposes a responsibility on the Revenue to ensure that it obtains the sanction of the specified authority before issuing a notice under section 148. The purpose behind this procedural check is to save the assesses from harassment resulting from the mechanical

Rajesh Batra, New Delhi vs. ITO Ward 29(1), Delhi

In the result ITA No.4420/Del/2025 is allowed

ITA 4421/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Dec 2025AY 2015-16

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 01Section 148Section 149(1)Section 149(1)(b)Section 250

given an interpretation that is consistent with the object and purpose of the Income-tax Act. …… 74. The above table indicates that the specified authority is directly co-related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping ... jurisdiction under section 148 to issue a reassessment notice. Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction. Section

Rajesh Batra, New Delhi vs. ITO, Ward 29(1), Delhi

In the result ITA No.4420/Del/2025 is allowed

ITA 4420/DEL/2025[2014-15]Status: DisposedITAT Delhi09 Dec 2025AY 2014-15

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 01Section 148Section 149(1)Section 149(1)(b)Section 250

given an interpretation that is consistent with the object and purpose of the Income-tax Act. …… 74. The above table indicates that the specified authority is directly co-related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping ... jurisdiction under section 148 to issue a reassessment notice. Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction. Section

Rajesh Batra, New Delhi vs. ITO Ward 29(1), Delhi

In the result ITA No.4420/Del/2025 is allowed

ITA 4419/DEL/2025[2012-13]Status: DisposedITAT Delhi09 Dec 2025AY 2012-13

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.4419, 4420 & 4421/Del/2025 िनधा"रणवष"/Assessment Years:2012-13, 2014-15 & 2015-16 बनाम Shri Rajesh Batra, Income Tax Officer, B-96, Shivalik, New Delhi. Vs. Ward 29(1), Pan No.Aahpb4919N Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 01Section 148Section 149(1)Section 149(1)(b)Section 250

given an interpretation that is consistent with the object and purpose of the Income-tax Act. …… 74. The above table indicates that the specified authority is directly co-related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping ... jurisdiction under section 148 to issue a reassessment notice. Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction. Section