“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

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.

CIT v. Mahendra C. Shah

299 ITR 305 · 2008 · High Court

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

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

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

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

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

Sanjeev Garg, New Delhi vs. ACIT, Circle 2(2)(2)(1), Ghaziabad

ITA 992/DEL/2024[2012-13]Status: DisposedITAT Delhi07 Nov 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Vipin Jain, FCAFor Respondent: Shri Manish Gupta, Sr. DR

Section 143(2)Section 147Section 148Section 151Section 292BSection 45Section 54

Ajit Gupta 383 ITR 361 (Del). ii) Secondly, the assessee challenged the grant of approval u/s 151 by specified Authority as without Page 3 of 20 [A.Y. 2012-13] Shri Sanjeev Garg reading the contents of the reasons and without application of mind. iii) the Assessing Officer while recording

Kalyani Koley, Howrah vs. CIT(A), Kolkata

Appeal of the assessee is allowed

ITA 227/KOL/2025[2013-14]Status: DisposedITAT Kolkata04 Nov 2025AY 2013-14

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 253(3)

Appeals) failed to consider that the said purported notice dated March 31, 2021 was issued without obtaining the requisite approvals of the specified authority as per the provisions of section 151(1) of the Act and the said notice was issued in violation of law and thus, void ab initio ... that the CIT(Appeals) have failed to consider that a copy of the purported approval, if any, passed by the specified authority should have been made over to the assessee and in the absence thereof, it can be safely assumed that the Assessing Officer is merely conducting a fishing

Uppalapadu Primary Agricultural Cooperative Society Limited, Uppalapadu, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

ITA 523/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam31 Oct 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan Sआ.अपी.सं /Ita No.523/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Uppalapadu Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-2(1), Society Limited, Guntur. Uppalapadu, Guntur. Pan: Aaaau4669G (Appellant) (Respondent) िनधा"रती Shri R. Siva Rama Krishna, "ारा/Assessee By: Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 29/10/2025 घोषणा की तारीख/Date Of 31/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Society Is Directed Against The Assessment Order Dated 25.01.2024 Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Read With Sections 144 & 144B Of The Income-Tax Act, 1961 (For Short, “The Act”) Dated 25.01.2024 For The Assessment Year 2018-19. The 2 Uppalapadu Primary Agricultural Cooperative Society Limited Vs. Ito

For Respondent: Dr. Aparna Villuri, Sr. AR

Section 139(1)Section 147Section 148Section 148ASection 80P

period of three years from the end of the relevant assessment year as envisaged in Section 151 of he 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 ... regarding the validity of the jurisdiction assumed by the A.O. for initiating proceedings u/s. 147 of the Act 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

ACIT, Circle -5(2)(1), Mumbai vs. Nasher Miles Private Limited, Mumbai

In the result, both the appeal filed by the revenue department stands dismissed, whereas the Cos

ITA 5078/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Oct 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankarassessment Year: 2016-17 & Assessment Year: 2017-18 Acit, Circle-5(2)(1) Nasher Miles Private Room No. 571, Aaykar Bhavan, Limited Mk Road, Mumbai- 400020, Vs. 1601, Panchratna Building, Mumbai Opera House, Girgaon, Mumbai- 400004 Pan: Aabcs1385E (Appellant) (Respondent)

For Appellant: Ms. Sheetal JainFor Respondent: Shri Layaqat Ali Aafaqui, Ld. Sr. A.R

Section 147Section 148Section 151Section 250

Mumbai-Trib.) quashed re-assessment order by mainly holding that the approval for issuing notice u/s 148 of the Act was not obtained by specified authority u/s 151(ii) of the Act i.e. Principle Chief Commissioner or Principle Director General or Chief Commissioner Or Director General, hence, following the judgment

ACIT-5(2)(1), Mumbai vs. Nasher Miles Private Limited, Mumbai

In the result, both the appeal filed by the revenue department stands dismissed, whereas the Cos

ITA 5077/MUM/2025[2016-17]Status: DisposedITAT Mumbai31 Oct 2025AY 2016-17

For Appellant: Ms. Sheetal JainFor Respondent: Shri Layaqat Ali Aafaqui, Ld. Sr. A.R

Section 147Section 148Section 151Section 250

Sejal Milan Vora, Mumbai vs. Income Tax Officer - 19(2)(4), Mumbai

In the result, the assessee’s appeal is allowed

ITA 4708/MUM/2025[2017-2018]Status: DisposedITAT Mumbai31 Oct 2025AY 2017-2018

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18

For Appellant: Shri Jigar MehtaFor Respondent: Shri Pushkaraj Bhangepatil, Ld. Sr.D.R

Section 147Section 148Section 148ASection 151Section 250Section 56(2)(vii)

section 151(ii) of the Act, according to which, if more than 3 years has been elapsed from the relevant assessment year, then the specified authorities for the purpose of section 148 shall be Principal Chief Commissioner or Principal Director General or where there is no such posts then ... Chief Commissioner or Director General would be the specified Authority. 5. Thus, this court on the aforesaid reason, is inclined to quash the notices u/s 148A(d) and 148 of the Act even dated 29.07.2022 along with assessment order dated 29.03.2023 u/s 147 r.w.s. 144B of the Act. Thus

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

statutory framework of section 151 and judicial pronouncements, held that the approval granted by the CIT (IT-1) was not by the “specified authority” prescribed under section 151(ii) as amended w.e.f. 1 April 2021. Since more than three years had elapsed from ... taken from the Commissioner of Income Tax and not PCCIT/CCIT. As per the amended provisions of section 151 of the Income Tax Act , the specified authority for giving sanction for section 148 and 148 A of the Act in the case of the appellant for the instant AY will

Dy. Commissioner of Income Tax, Jaipur vs. Hem Chand Jain, Jaipur

In the result, appeal of the Revenue is dismissed and Cross Objection of the assessee is allowed

ITA 670/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT &

Section 147Section 148Section 148ASection 151Section 250

dated 23/07/2022 (copy enclosed) was obtained from PCIT-1 (Jaipur). As per section 151 as applicable when the notice u/s 148 was issued, the specified authority for the purpose of section 148 and section 148A is PCCIT if more than 3 years have been lapsed from ... relevant AY. For ready reference section 151 is reproduced as under:- “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 than three years have elapsed

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

issue of notice shall be subject to the provisions of section 151.] 7 ITA No.2225/PUN/2025 [A] Section – 151 : [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 ... Company Vs. ACIT 175 taxmann.com 453(MADRAS) dated 05.06.2025 has held as under : “9. A perusal of Section 151(i) would show that, the specified authority 10 for the purpose of issuing notice underSection 148 within a period of ITA No.2225/PUN/2025 [A] three years from the end of the relevant

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

assessee has referred to provisions of section 151 of the Act and has submitted that as per section 151 of the Act specified authority for the purpose of section 148 and 148A of the Act is Principal Commissioner or Principal Director or Commissioner or Director if three years or less ... ld.Principal Commissioner of Income Tax-1, Nashik. 4.3 Section 151 of the I.T.Act is reproduced here as under : [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

Satish Vishnu Thombare, Income Tax Officer, Ward-1, Ahmednagar vs. Varsha Prafulla Zende, Ahmednagar

In the result, the appeal of the Revenue is dismissed

ITA 1656/PUN/2024[2010-11]Status: DisposedITAT Pune29 Oct 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

For Appellant: Miss Shivani Shah (Virtual)For Respondent: Shri Akhilesh Srivastva

Section 132(1)Section 147Section 148Section 151Section 68

furnished a copy of the approval necessary before issuing notice. Petitioner contends that said approval was signed at 2.55 p.m. on 31/03/2019 by the specified authority under Section 151 of the Act. 6. On 26/04/2019, Petitioner filed the original return of income in response to the said notice under Section

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4671/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

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

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

issued for AY 2016-17 CO Nos.126, 104 & 105/Del/2025 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 vs. Rajeev Bansal ... been provided that no notice under Section 148 of the Act shall be issued unless the AO has obtained prior approval of the specified authority to issue such notice and the specified authority for the purpose of this section has been defined in Section 151 of the Act. Section

DCIT, Circle - 10(1), New Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4670/DEL/2024[2015-16]Status: DisposedITAT Delhi29 Oct 2025AY 2015-16

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

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4669/DEL/2024[2011-12]Status: DisposedITAT Delhi29 Oct 2025AY 2011-12

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

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

Rakshit Estates Private Limited, Gurgaon vs. Income Tax Officer, Gurgaon

In the result, appeal of assessee is allowed

ITA 3615/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandrarakshit Estates Private Vs. Income Tax Officer, Hsiidc Limited. Building, Vanijya Nikunj, Plot No. 11, Basement, J 2.1, Udhyogvihar, Phase-V, Sector 83, Gurgaon, Haryana Gurgaon, Haryana Pan: Aagcr0135G Appellant Respondent Assessee By Sh. Ramesh Chander, Adv Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 24/09/2025 Date Of Pronouncement 29/10/2025

Section 131Section 143(2)Section 143(3)

vide his order passed u/s.143(3) dated 30.03.2015, then, as per the mandate of sub-section (1) of Section 127 of the Act, the specified authority i.e. Commissioner or above was 15 Rakshit Estates Pvt. Ltd. Vs. ITO obligated to have recorded his reasons for transferring the case from

Anupama Vintrade Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1313/KOL/2025[2015-16]Status: DisposedITAT Kolkata27 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Anupama Vintrade Pvt. Ltd..….……………………….……….……….……Appellant 77, 4Th Floor, Room 422, Elliot Road, Kol-700016.. [Pan: Aahca5675R] Vs. Ito, Ward-10(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Somnath Ghosh, Advocate, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.03.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Appeal Has Been Filed By The Assessee With A Delay Of 14 Days. 2. The Assessee Has Filed An Affidavit For Condonation Of The Delay. After Considering The Reasons Cited In The Affidavit For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 133(6)Section 143(1)Section 147Section 148Section 148ASection 149(1)(b)Section 250

consistent with the object and purpose of the Income-tax Act. …… 4 Anupama Vintrade Pvt. Ltd 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 5 Anupama Vintrade Pvt. Ltd sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant

ITO, Ward 10(2), Kolkata vs. Alex Tradecom Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2198/KOL/2024[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2197 & 2198/Kol/2024 Assessment Years: 2013-14 & 2014-15 Ito, Ward-10(2), Kolkata…………..…………………………….…….……Appellant Vs. Alex Tradecom Pvt. Ltd…………..……………….………...……...…..…..Respondent 4, Ratan Sarkar Garden Street, Burrabazar, Kol- 700069. [Pan: Aajca6146P] Appearances By: Smt. Madhumita Das, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Akshay Ringasia, Ca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Revenue For The Assessment Years 2013-14 & 2014-15 Against Separate Orders Dated 05.08.2024 & 26.07.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. Both The Appeals Have Been Filed By The Revenue With Delays Of 38 Days. The Revenue Has Filed Separate Affidavits For Condonation Of The Delays. After Considering The Reasons Cited In The Affidavits For Condonation Of Delay, We Find That The Reasons Are Valid And

Section 148Section 148ASection 250

relevant assessment years u/s.149(1)(b) of the old regime. From para 73 to 76, the Lordships have elaborated the sanction of specified authority u/s.151 vis-à-vis the time limit prescribed in Section 151. For the sake of ready reference para 73-76 reads as under:- "73. Section ... 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

ITO, Ward-10(2), Kolkata vs. Alex Tradecom Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2197/KOL/2024[2013-14]Status: DisposedITAT Kolkata27 Oct 2025AY 2013-14

Section 148Section 148ASection 250

Shri Sati Hosiery Pvt Ltd, Delhi vs. ITO Ward-23(3), Delhi

In the result, appeal of assessee in ITA No

ITA 1804/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Oct 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Dinesh Bansal, CAFor Respondent: Shri Sushil Kumar Kulheri, Sr. DR

Section 148Section 148ASection 151

amended provisions, have been initiated after lapse of more than 3 years, therefore the provision of section 151(ii) will kick in. The specified authority to grant approval for reopening the assessment, passing order u/s 148A(d) and issuing notice u/s 148, where more than three years have lapsed from ... their absence, the Chief Commissioner or Director General, instead of the Principal Commissioner of Income-tax, who did not fall within the specified authorities outlined in section 151 of the Act. Hence the notice of reassessment dated May 26, 2022 and July 30, 2022 and the order dated July

Income Tax Officer, Income Tax Office vs. Ritu Bala, Faridabda

In the result, the appeal of Revenue is dismissed

ITA 3621/DEL/2024[2018-19]Status: DisposedITAT Delhi27 Oct 2025AY 2018-19

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2018-19 Income Tax Officer, Ritu Bala, Vs. Faridabad 4237 Indra Prashtha Colony, Haryana Faridabad – 121 001 Haryana Pan :Bdhpb1495B (Appellant) (Respondent)

Section 142(1)Section 144Section 144BSection 148Section 148ASection 250Section 250(4)Section 69C

Brief facts of the case are that as per order under Section 148A(d) of the Act dated 31.03.2022 was passed with approval of specified authority along with notice under Section 148 of the Act. In case of assessee, specific information was flagged as per Risk Management Strategy formulated