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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

Vallabhbhai Bhagvanjibhai Kathiriya, Jamnagar vs. ITO Ward 2(10) Jamnagar, Jamnagar

In the result, appeal filed by the assessee, in ITA, No

ITA 510/RJT/2025[2013-14]Status: DisposedITAT Rajkot24 Nov 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 271ASection 69A

remained unexplained." Based on the above information, a show-cause notice u/s 148A(b) of the Act was issued with the approval of the specified authority. In response, assessee made certain submission including objection against reopening of the assessment and the same was disposed-off by the Jurisdictional Assessing Officer

Sathi Bhai Sathyavrithan, Delhi vs. Income Tax Officer Ward 68(1), Civic Centre, New Delhi 110002, Delhi

Appeal is allowed

ITA 6274/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Sathi Bhai Sathyavrithan, Rz 31-32, Roshan Mandi Ward-68(1), Surya Kiran Hospital, New Delhi Najafgarh, New Delhi Pan: Ayqps2816L (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

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

Neelam Jain, Delhi vs. Income Tax Officer Ward 36(1) Civic Centre, New Delhi 110002, Delhi

Appeal is allowed

ITA 6261/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Vs. Income Tax Officer, Neelam Jain, 374, Veer Apartment, Ward-36(1), Sector-103, Rohini, New Delhi Delhi Pan: Ajppj0908E (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Department By Sh. Manoj Kumar, Sr. Dr

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

Navinbhai Ratilal Idria, Surat vs. ITO, Ward 2(3)(4), Surat

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

ITA 694/SRT/2025[2014-15]Status: DisposedITAT Surat21 Nov 2025AY 2014-15

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

Section 144Section 147Section 148Section 148ASection 271(1)(c)

regime if time limit of three years from end of an assessment year falls between 20 March 2020 and 31 March 2021, then specified authority under section 151(i) has an extended time till 30 June 2021 to grant approval Held, yes Whether in case of section ... regime, if time limit of four years from end of an assessment year falls between 20 March 2020 and 31 March 2021, then specified authority under section 151(2) has time till 31 March 2021 to grant approval - Held, yes (Partly in favour of revenue]." 7.1. This judgment was followed

K.Y.S. Sponge Iron Pvt. Ltd., Kolkata vs. I.T.O., Ward - 3(1), Kolkata

Appeal of the assessee is allowed

ITA 2092/KOL/2025[2017-2018]Status: DisposedITAT Kolkata21 Nov 2025AY 2017-2018

Bench: Any Other Issue.

Section 148Section 148ASection 149(1)(b)Section 250Section 68Section 69A

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

Mukeshkumar Bhawarlal Jain, Mumbai vs. ITO 23(2)(6), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6694/MUM/2024[2014-15]Status: DisposedITAT Mumbai21 Nov 2025AY 2014-15

Bench: Smt Beena Pillai & Smt.Renu Jauhri7 (A.Y.2014-15)

For Appellant: Mr. Suchek AnchaliyaFor Respondent: Shri Annavaran Kosuri- Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 250Section 69A

erred in holding the notice issued u/s 148 of the Act as valid without appreciating the fact that the prior approval of the specified authority u/s 151(ii) of the Act was granted in a mechanical manner without any application of mind. The appellant craves to add, alter, classify, reclassify

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

Director General of Income Tax. The relevant provisions are quoted below as these stood on 1/4/2022. [Sanction for issue of notice. 151. 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 ... Director General of Income Tax. The relevant provisions are quoted below as these stood on 1/4/2022. [Sanction for issue of notice. 151. 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

Durga Prasad Sharma, Jaipur vs. I.T.O. Ward 1(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1038/JPR/2025[A.Y. 2018-19]Status: HeardITAT Jaipur20 Nov 2025

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

For Appellant: Sh. G. M. Mehta, CAFor Respondent: Sh. Ghanshyam Meena, JCIT
Section 115BSection 148Section 2Section 69C

follow the procedure of newly inserted provisions of section 148A of Income tax Act, i.e. to conduct enquiry with the prior approval of specified authority (section 148A(a) of Income tax Act), thereafter under section 148A (b) 12 Durga Prasad Sharma vs. ITO of Act to serve a notice

Manish Jashwantrai Bhuta, Nashik vs. ITO Ward 1(1), Nashik

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

ITA 1502/PUN/2025[2016-17]Status: DisposedITAT Pune20 Nov 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Manish Jashwantrai Bhuta Ito, Ward 1(1), Nashik Flat No.8, Pooja Apartment, Vs. Shivam Nagar, Hirawadi, Panchavati, Nashik – 422003 Pan: Aghpb1619F (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi (Through Virtual) Department By : Shri Manish M. Mehta Date Of Hearing : 03-11-2025 Date Of Pronouncement : 20-11-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Sanket M Joshi (through virtual)For Respondent: Shri Manish M. Mehta
Section 132Section 147Section 148Section 148ASection 151Section 153CSection 68

escaped assessment in the case of the assessee for the relevant assessment year and the AO has obtained prior approval of the specified authority to issue such notice: Provided further that no such approval shall be required where the AO, with the prior approval of the specified authority, has passed ... books of account or documents are seized or requisitioned in case of any other person. Explanation. 3. For the purposes of this section, specified authority means the specified authority referred to in s. 151." 7. A perusal of the above provision would show that, before issuing any notice under

ITO(It)-3(2)(1), Mumbai vs. Shapoorji Pallonji Mistry, Mumbai

ITA 3674/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Nov 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

wherein it has been specified that fresh notice under section 148 is to be issued for AY 2016-17 with the approval of the specified authority under clause (i) of section 151 of the Act, i.e., the Pr.CIT/Pr.DIT or the CIT/DIT. 5. Whether on the facts ... section 148A, for the Assessing Officer to comply with, mentions that – i.Assessing Officer shall conduct any enquiry, if required, with the approval of the specified authority, with respect to information which suggests that income chargeable to tax has escaped assessment. ii.He shall provide an opportunity of being heard

Income Tax Officer (It)-3(2)(1), Kautilya Bhawan vs. Shapoorji Pallonji Mistry, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 3523/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Nov 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. Advocate and Shri Divesh Chawla, AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

wherein it has been specified that fresh notice under section 148 is to be issued for AY 2016-17 with the approval of the specified authority under clause (i) of section 151 of the Act, i.e., the Pr.CIT/Pr.DIT or the CIT/DIT. 5. Whether on the facts ... section 148A, for the Assessing Officer to comply with, mentions that – i.Assessing Officer shall conduct any enquiry, if required, with the approval of the specified authority, with respect to information which suggests that income chargeable to tax has escaped assessment. ii.He shall provide an opportunity of being heard

Income Tax Officer (International Taxation) 3(2)(1), Kautilya Bhawan Mumbai vs. Shapoorji Pallonji Mistry, Mumbai

ITA 3440/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Nov 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

wherein it has been specified that fresh notice under section 148 is to be issued for AY 2016-17 with the approval of the specified authority under clause (i) of section 151 of the Act, i.e., the Pr.CIT/Pr.DIT or the CIT/DIT. 5. Whether on the facts ... section 148A, for the Assessing Officer to comply with, mentions that – i.Assessing Officer shall conduct any enquiry, if required, with the approval of the specified authority, with respect to information which suggests that income chargeable to tax has escaped assessment. ii.He shall provide an opportunity of being heard

Anjaneyulu Reddy Ammireddy, Vinukonda vs. Income Tax Officer, Ward-1, Narasaraopet

ITA 542/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.542/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Vs. Anjaneyulu Reddy Ammireddy, Income Tax Officer, Vinukonda. Ward-1, Pan: Aelpa3332C Narasaraopet. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Gvn Hari, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 06/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 25/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 29/02/2024. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal:

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 151Section 151ASection 69

beyond the period of three years from the end of the assessment year, i.e., AY 2018-19, without obtaining the prior approval of the specified authority as contemplated under section 151 of the Act. The Ld. AR to buttress his contention had drawn our attention to the notice under section ... three years from the end of the relevant assessment year, therefore, the AO was statutorily obligated to have obtained the approval of he specified authority as contemplated in r section 151(ii) of the Act (as was then available on the statute), i.e., the 8 Anjaneyulu Reddy Ammireddy

Ashok Rudraraju, Visakhapatnam vs. Income-Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 439/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 439/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) Ashok Rudraraju, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Visakhapatnam. Pan: Aqvpr4058L

For Appellant: Shri I. Kama Sastry, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 151(1)Section 151ASection 251(1)(a)Section 69A

period of three years from the end of the relevant assessment year as envisaged in Section 151 of the Act, based on which the specified authority whose sanction is required to be obtained for issuing notice under Section 148 of the Act is to be determined, the period allowed ... 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

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

Court in the case of Union of India v. Rajeev Bansal [2024] 469 ITR 46 (SC) wherein it was held: iii. Sanction of the specified authority 73. Section 151 imposes a check upon the power of the Revenue to reopen assessments. The provision imposes a responsibility on the Revenue ... 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 reopening of assessments.128 A table representing the prescription under the old and new regime

Kineta Global Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

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

ITA 800/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, 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, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

For Appellant: Sri S. VenkateswarluFor Respondent: Dr. Narendra Kumar Naik
Section 147Section 148Section 148ASection 151Section 151ASection 250(6)

same were issued in contravention to provisions of section 151 of the Act in respect of issue of Specified authority and hence the subsequent proceedings and the assessment order dated 21.02.2024 are to be held as invalid. (Additional Ground) 3. The order u/s 148A(d) dated 21.04.2022 and notice ... period of three years from the end of the relevant assessment year as envisaged in Section 151 of the Act, based on which the specified authority whose sanction is required to be obtained for issuing notice under Section 148 of the Act is to be determined, the period allowed

Praveen Kumar Diddige, Medak vs. Income Tax Officer, Ward-1, Sangareddy

In the result, appeal of the Assessee is allowed

ITA 1370/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1370/Hyd/2025 Assessment Year – 2017-2018 Praveen Kumar The Income Tax Officer, Diddige, Medak Ward-1, Sangareddy. Vs. Pin – 502 291. Pin – 502001. Pan Aeapd8792G Telangana. (Appellant) (Respondent) Ca Pv Raghavendra Kumar िनधा"रती "ारा /Assessee By: & Ca K A Sai Prasad राज" व "ारा /Revenue By: Sri R. Kumaran, Sr. Ar

For Appellant: And CA K A Sai PrasadFor Respondent: Sri R. Kumaran, Sr. AR
Section 144Section 147Section 148Section 151

u/sec.148 of the Act after 1st April, 2021 falls under New Scheme of re-assessment proceedings and as per sec.151, the approval of the Specified Authority as specified therein should be obtained. According to the assessee, under New Scheme of re-assessment proceedings, the Specified Authority u/sec ... after a period of three years from the end of the relevant assessment year, the Principal Chief Commissioner or Principal Director General are the Specified Authority(ies). Since in the present case, the Assessing Officer has issued notice u/sec.148 of the Act dated 30.07.2022 after approval from Principal Commissioner

Ramasamy Kandasamy, Karur vs. ITO, Ward-1, Karur

In the result, the appeal of the assessee is allowed

ITA 2023/CHNY/2025[2012-13]Status: DisposedITAT Chennai19 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.2023/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 V. Ramasamy Kandasamy, The Ito, No.4/76, Sf No.927, Sukkaliyur, Ward-1, Karur-639 003. Karur. [Pan: Ajgpk 4945 H]

For Appellant: Mr.H. Yeshwanth KumarFor Respondent: Ms.R. Anitha, Addl.CIT
Section 143(2)Section 143(3)Section 147Section 151

vague reasons and non- availability of details. By filing RTI application the appellant had requested to supply the approval u/s 151 by the specified authority to reason recorded by the AO. The department has denied supplying the approval of the reasons recorded by the AO, on the basis of confidentiality ... case under reference. 4.5. The AO had issued notice u/s 148 after obtaining approval u/s 151 of the Income Tax Act from the specified authority. The AO duly recorded his satisfaction for reopening of the case, thereafter he put up the same with relevant record before the specified authority

Income Tax Officer, Ward-14(3), New Delhi vs. Kolahai Infotech Private Limited, New Delhi

In the result the appeal of the Revenue is dismissed

ITA 3399/DEL/2025[2015-16]Status: DisposedITAT Delhi19 Nov 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2015-16 Income Tax Officer, Vs. Kolahai, Infotech Private Limited Ward-14(3) , Room 129, First Floor Transport Centre No.305 Cr Building I.P. Punjabi Bagh New Delhi, Delhi- Estate New Delhi -110002 110034

Section 139Section 143(3)Section 147Section 148Section 148ASection 149(1)Section 14ASection 68

case of Ashish Agarwal (Supra) in new regime (as Amended by finance Act, 2021) of the Income Tax Act, 1961 after approval of specified authority. The escapement income of instant case is more than fifty lakh, the case covered u/s 149(1) (b) of the Act. As per new regime ... issued as per the direction of the Hon’ble Supreme Court in the case of Ashish Agarwal after obtaining the approval of the specified authority. It was also submitted that it was wrongly held that the notice issued under section 148 of the Act is time barred. In this case

Dileep K Gupta, Delhi vs. DCIT CC-31, Delhi

In the result, the appeals of the assessee are allowed

ITA 153/DEL/2025[2021-22]Status: DisposedITAT Delhi19 Nov 2025AY 2021-22

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Amit Jain, CIT DR
Section 132Section 139Section 143(3)Section 153ASection 153D

treatment and thus prevents bias, prejudice and arbitrariness. It also prevents and avoids inconsistent and divergent views. The power of approval to the specified authority i.e., Superior authority has been envisaged with the objectives that no illegality or biasness, to either of the sides i.e., the assessee or the Revenue