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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

Mahesh Gokuldas Fulwani, Aurangabad vs. ITO Ward 1(1) Aurangabad, Aurangabad

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

ITA 873/PUN/2025[2017-2018]Status: DisposedITAT Pune30 Jul 2025AY 2017-2018

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Mahesh Gokuldas Fulwani Ito, Ward 1(1), Mahesh Traders C O Girls Fashion, Aurangabad Vs. 2/7/63, Tilak Path, Paithan Gate, Aurangabad- 431001 Pan: Aajpf4456C (Appellant) (Respondent) Assessee By : Shri Girish Ladda Department By : Shri Ramnath P Murkunde Date Of Hearing : 28-07-2025 Date Of Pronouncement : 30-07-2025 O R D E R

For Appellant: Shri Girish LaddaFor Respondent: Shri Ramnath P Murkunde
Section 148Section 148ASection 151

/PCIT-4/Proposal/2022-23/1272 dated 27/07/2022.” 23. Provisions of section 151 as it stood at the relevant time read 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 ... Principal Director General, Chief Commissioner or Director General. The Hon’ble High Court further held that TOLA would have no relevance for determining the specified authority whose approval was mandatory under section 151 for issuance of a notice under section 148 and the bifurcation of those powers would continue unaltered

DCIT, Central Circle-1(4), Kolkata vs. Kailash Kumar Tibrewal, Kolkata

In the result, the appeal filed by the appellant is Allowed

ITA 627/KOL/2025[2016-17]Status: DisposedITAT Kolkata30 Jul 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Altaf Hussain, DR
Section 132(1)Section 143(1)Section 271(1)(c)Section 275Section 275(1)(c)

imposing an penalty of Rs. 1,21,15,075/- after obtaining necessary prior approval u/s. 274(2) of the act on 31.03.2022from the specified authority. The same is hereby enclosed for ready reference. It is further communicated that above penalty order passed on 31.03.2022 vide DIN No. ITBA/COM/M/17/2022-23/1042842838 ... time limit for passing the order. However, in the instant case, on the very last day of penalty proceeding, after seeking prior approval from specified authority, the penalty order u/s. 271(1)(c ) was passed on 31.03.2022. Further, it is very usual that there might be heavy traffic

DCIT, Central Circle-1(4), Kolkata vs. Kailash Kumar Tibrewal, Kolkata

In the result, the appeal filed by the appellant is Allowed

ITA 626/KOL/2025[2015-16]Status: DisposedITAT Kolkata30 Jul 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Altaf Hussain, DR
Section 132(1)Section 143(1)Section 271(1)(c)Section 275Section 275(1)(c)

imposing an penalty of Rs. 1,21,15,075/- after obtaining necessary prior approval u/s. 274(2) of the act on 31.03.2022from the specified authority. The same is hereby enclosed for ready reference. It is further communicated that above penalty order passed on 31.03.2022 vide DIN No. ITBA/COM/M/17/2022-23/1042842838 ... time limit for passing the order. However, in the instant case, on the very last day of penalty proceeding, after seeking prior approval from specified authority, the penalty order u/s. 271(1)(c ) was passed on 31.03.2022. Further, it is very usual that there might be heavy traffic

M/S. Life Insurance Corporation of India, Mumbai vs. Addl CIT Circle 3(2)(1), Mumbai

In the result, the appeal filed by the assessee stands partly allowed for statistical purpose

ITA 3709/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 156

issuing a notice u/s 148 of the Act dated 31.03.2021, after obtaining necessary approval of the specified authority u/s. 151 of the Act. In response thereto, the assessee filed its return of income on 31.05.2021, declaring a total Income of Rs.25,036,12,03,250/-, being the total income declared

Ajay Duggal, New Delhi vs. Income Tax Officer 72(1), New Delhi

In the result, appeal of the assessee is partly allowed as

ITA 5612/DEL/2024[2016-17]Status: DisposedITAT Delhi30 Jul 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.5612/Del/2024 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Ajay Duggal Income Tax Officer, C-138, Vivek Vihar, Vs. Ward-72(1), Anand Vihar, S.O., Aayakar Bhawan, East Delhi. Delhi. Pan No.Aglpd6006C अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 151Section 151(2)

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 ... reopening of assessments. A table representing the prescription under the old and new regime is set out below: Regime Time limits Specified authority Section 151(2) Before expiry of four years from Joint Commissioner of the old the end of the relevant regime assessment year Section 151(1) After expiry

Kavita Satish Sethi, Powai Mumbai vs. Income Tax Officer Ward 41 1 2 Mumbai, Mumbai

In the result, appeal filed by the Assessee is allowed

ITA 2165/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Jul 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2017-18

For Appellant: Shri Jitendra Singh, Ld. A.RFor Respondent: Shri Hemanshu Joshi, Ld. Sr. D.R
Section 147Section 148Section 151Section 250

Assessee has raised the legal issue pertaining to the issuing of notice u/s 148 of the Act not being sanctioned by the Specified Authority, as enshrined in section 151 of the Act and as applicable to the case of the Assessee, first time before this Court and therefore ... adjudication. 3. Coming to the legal ground raised by the Assessee qua issuance of notice u/s 148 of the Act without getting sanction from Specified Authority, as empowered by section 151 of the Act, we observe that in this case, admittedly, the case of the Assessee was reopened

Sri Lanka Cricket, Sri Lanka vs. Assistant Commissioner of Income Tax (International Tax) Circle- 3 (1)(2), New Delhi

ITA 1603/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Jul 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 14Section 147Section 148Section 148ASection 154Section 234ASection 234BSection 270A

approved by the Commissioner of Income Tax, (International Tax), Delhi- 3, instead of the Principal Chief Commissioner of Income-Tax, International Taxation, the specified authority mentioned under section 151 of the Act as the case of the assessee was reopened. Further, it was argued that the notice under section 148A/148

Sylvan Greens Private Limited, Jaipur vs. Deputy Commissioner of Income Tax Circle 6, Jaipur

In the result, the appeal of the assessee is allowed

ITA 414/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16

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

For Appellant: Smt. Neelam Bhala, AdvocateFor Respondent: Shri Gorav Avasthi, JCIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 801C

Officer V Tia Enterprises (P.) Ltd, SLP dismissed against order of High Court that where Assessing Officer did not obtain prior approval of specified authority, impugned notice issued under section 148 was liable to be quashed. 3. The Hon'ble Commissioner of Income tax appeals has further not justified ... High 28 ITA NO.414.JPR/2025 SYLVAN GREEN PRIVATE LTD VS DCIT,CIRCLE-6 , JAIPUR Court where Assessing Officer did not obtain approval of specified authority and the impugned notice issued u/s 148 was liable to be quashed. 2.7 Further, it is noticed that the ld.CIT(A) confirmed the addition made

Chokkalingam Thangavel, Agasteeswaram, Kanyakumari vs. Income Tax Officer, Ward-1, Nagercoil, Income Tax Office

Appeal of the assessee is allowed

ITA 577/CHNY/2025[2018-2019]Status: DisposedITAT Chennai25 Jul 2025AY 2018-2019

Bench: Shri George George K & Ms Padmavathy S, Am

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Dr. M. Sri Shanmuga Priya, JCIT
Section 139Section 147Section 148Section 148ASection 151Section 250Section 69A

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: [Provided further that no such approval shall be required where the Assessing Officer, with the prior approval of the specified authority ... 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 section 151]." 7. A perusal of the above provision would show that, before issuing any notice under Section

Income Tax Officer, Mumbai vs. Naresh Jaiprakash Shroff, Mumbai

In the result, appeal of the revenue and cross-objection by the assessee

ITA 2793/MUM/2025[2017-18]Status: DisposedITAT Mumbai25 Jul 2025AY 2017-18

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Shri Subodh Ratnaparkhi, A/RFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. D/R
Section 148Section 149Section 151Section 151(2)Section 3(1)

time-limit of three years from the end of an assessment year falls between 20-3-2020 and 31-3-2021, then the specified authority under section 151(i) has extended time till 30-6-2021 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 20-3-2020 and 31-3-2021, then the specified authority under section 151(2) has extended time till 31-3-2021 to grant approval; (f) The directions in Ashish Agarwal (supra) will extend

Pramod Lakra Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Urvashi Sarees Pvt. Ltd, Kolkata

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

ITA 222/KOL/2025[2015-16]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-16

Bench: ITAT, Kolkata were collected and prepared | | 18.01.2025 | 2nd Appeal was filed |

Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69C

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

Urvashi Sarees Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

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

ITA 1946/KOL/2024[2015-2016]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-2016

Bench: ITAT, Kolkata were collected and prepared | | 18.01.2025 | 2nd Appeal was filed |

Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69C

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

Packswell Combine Pvt Ltd, Mumbai vs. DCIT Central Circle 6(4), Mumbai

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

ITA 234/MUM/2025[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankarpackswell Combine Pvt. Ltd. Vs. Deputy Commissioner 602, 6Th Floor, Amrit ‘A’ Of Income Tax Officer, Carter Road, Khar Danda, Central Circle 6(4), Khar (W), Mumbai- 400052 Mumbai Kautilya Bhavan, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051 Pan/Gir No. Aaacp3076C (Applicant) (Respondent)

Section 147Section 148Section 148ASection 151Section 250

Packwell Combine Pvt. Ltd. Provisions of section 151 of the Act under the new law read 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 ... above, the notice issued u/s 148 of the Act on 29/07/2022 for A.Y 2016-17 is issued without obtaining prior approval from the specified authority as per section 151 of the Act. Accordingly, the notice issued u/s 148 of the Act for A.Y 2016-17 is invalid and the consequent

Deepak Singhal, Delhi vs. ITO Ward 36(1), New Delhi

Appeal is allowed in above terms

ITA 3355/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Jul 2025AY 2017-18

Bench: SHRI SATBEER SINGH GODARA (Judicial Member)

Section 147Section 148Section 151Section 151(1)Section 151(2)

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 ... mechanical reopening of assessments. 128 A table representing the prescription under the old and new regime is set out below: Regime Time limits Specified authority Section 151(2) of Before expiry of four Joint the old regime years from the end of the Commissioner relevant assessment year Section

Neha Goel, Delhi vs. Income Tax Officer, Delhi

Appeal is allowed in above terms

ITA 1728/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Jul 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Neha Goel, Vs. Income Tax Officer, F-22/35, Sector-3, Rohini, Delhi Delhi Pan: Ajspb1120D (Appellant) (Respondent)

Section 147Section 148Section 151Section 151(1)Section 151(2)

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 ... reopening of assessments. 128 A table representing the prescription under the old and new regime is set out below: Regime Time limits Specified authority Section 151(2) of Before expiry of four Joint the old regime years from the end of the Commissioner relevant assessment year Section

M/S Karia Builders, Pune vs. ITO Ward 14(3), Pune

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

ITA 2401/PUN/2024[2017-18]Status: DisposedITAT Pune23 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 M/S. Karia Builders Ito, Ward 14(3), Pune 402, Konark Indrayu, Kondhwa, Vs. Pune – 411048 Pan: Aadfk5220B (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi Department By : Shri Ramnath P Murkunde Date Of Hearing : 17-07-2025 Date Of Pronouncement : 23-07-2025 O R D E R

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Ramnath P Murkunde
Section 147Section 148Section 269SSection 271DSection 274Section 275(1)Section 296S

/PCIT-4/Proposal/2022-23/1272 dated 27/07/2022.” 23. Provisions of section 151 as it stood at the relevant time read as under: “Sanction for issue of notice. 151. Specified authority for the purposes of section 148 and section 148A shall be,— 12 (i) Principal Commissioner or Principal Director or Commissioner or Director, if three ... Principal Director General, Chief Commissioner or Director General. The Hon’ble High Court further held that TOLA would have no relevance for determining the specified authority whose approval was mandatory under section 151 for issuance of a notice under section 13 148 and the bifurcation of those powers would continue

Piyush Kumar Sarda, Kolkata vs. ITO, Ward 44(2), Kolkata

In the result, appeal of the assessee is allowed

ITA 542/KOL/2025[2018-19]Status: DisposedITAT Kolkata23 Jul 2025AY 2018-19

Bench: Shri George Mathanआयकर अपील सं/Ita No.542/Kol/2025 (नििाारण वर्ा / Assessment Year :2018-19) Piyush Kumar Sarda Vs Income Tax Officer, Ward 44(2) 3/1B, Sir Hari Ram Goenka Street, 3, Government Place (West), Kolkata-700001, West Bengal Kolkata-700001, West Bengal Pan No. : Atbps 4944 D (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Sunil Surana, Ar राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 23/07/2025 घोषणा की तारीख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Shankar Naskar, Sr. DR
Section 147Section 148Section 148ASection 3

guidelines a provision that the order under Section 148A(d) of the Act shall be sent to assessee along with the approval of the specified authority for such order under Section 148A(d) of the Act. In the case at hand, the approval that has been sent is of some

Albert Joseph Rozario, Mumbai vs. ITO, Int. Tax, Circle 4(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1168/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jul 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Albert Joseph Rozario, Ito, (Int. Tax), Circle-4(1)(1), B-311, 5Th Wing, Room No. 629, 6Th Floor, Inlaks Park, Vs. Kautilya Bhavan, Yari Road, Versova, C-41 To C-43, G Block, Andheri West, Bandra Kurla Complex, Mumbai-400058 Bandra East, Pan : Afvpr6139P Mumbai-400051 (Appellant) (Respondent) For Assessee : Shri Dharan Gandhi For Revenue : Shri Sridhar G. Menon, Sr.Dr Date Of Hearing : 01-05-2025 Date Of Pronouncement : 22-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Final Assessment Order Passed By The Assessing Officer U/S 147 R/W 144C(13) Of The Act Dt. 30-12-2024, Consequent To The Directions Given By The Ld. Drp-1, Mumbai-3, U/S 144C(5) Of The Act, Dated 30-11-2024 Pertaining To Assessment Year (Ay.) 2018-19. 2. Briefly The Facts Of The Case Are That Basis Information Available Through The Insight Portal That The Assessee Had Purchased Immoveable Properties Amounting To Rs. 8,31,45,549/- & Has Received Interest

For Appellant: Shri Dharan GandhiFor Respondent: Shri Sridhar G. Menon, Sr.DR
Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 56(2)(x)Section 69

notice of reassessment under section 5 148 within the prescribed time limits. Further, Section 151 requires assessing officers to obtain sanction of the specified authority before issuing notice under section 148. In Chhugamal Rajpal v. S P Chaliha, [1971] 79 ITR 603 (SC), a three-Judge Bench of this Court ... 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

Vinita Bajoria, Jaipur vs. Income-Tax Officer, Jaipur

In the result, the appeal of the assessee is allowed

ITA 370/JPR/2025[201617]Status: DisposedITAT Jaipur21 Jul 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 370/JP/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Vinita Bajoria 1, Ganesh Colony Moti Doongri Road, Jaipur बनाम Income Tax Officer, Ward 5(2), Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AEBPB4873M अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Manoj Choudhary, CA राजस्व की ओर से / Revenue by : Sh. Gorav Avasthi, JCIT सुनवाई की तारीख / Date of Hear

For Appellant: Sh. Manoj Choudhary, CAFor Respondent: Sh. Gorav Avasthi, JCIT
Section 147Section 148Section 148A

entire re-assessment proceedings (No submission has been made by the Ld. DR on this ground of Appeal). c) Necessary sanction of the specified authority as provided in section 151 of the Act has not been taken by the Assessing Officer while reopening of the assessment. According to the section ... thus, notice issued u/s.148 after lapse of 3 years is bad in law, since the same has been issued without obtaining the approval from Specified authority viz. Pr. CCIT prescribed u/s.151(ii), thereby violating the law settled by Hon'ble Apex Court in the case of UOL vs. Rajeev Bansal

Amrit Pal Singh Chadha, Gurgaon vs. ACIT, Central Circle-19, New Delhi

Appeal is allowed in above terms

ITA 2794/DEL/2025[2014-15]Status: DisposedITAT Delhi21 Jul 2025AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 2794/Del/2025 : Asstt. Year: 2014-15 Amrit Pal Singh, Vs Acit, 4410, Dlf, Phase-Iv, Central Circle-19, Gurgaon, Haryana-122002 New Delhi-110055 (Appellant) (Respondent) Pan No. Aewpc3215P Assessee By: Sh. Amar Jeet Singh, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 21.07.2025 Date Of Pronouncement: 21.07.2025 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2024-25/1073779465(1) Dated 27.02.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Amar Jeet Singh, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 13ASection 147Section 148Section 148ASection 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