“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

Dharmendra Rikhavchand Shah, HUF, Himatnagar vs. NFAC, Delhi Present Huris.the ITO, Ward-1, Himatnagar

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

ITA 2680/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR

Section 115BSection 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 148ASection 151Section 151A

circumstances of the case, the approval granted u/s 151 is mechanical in nature as well as the same lacks the signature of the specified authority which vitiates the entire reassessment proceedings. 5. In law and on the facts and in the circumstances of the case, the Ld. AO had erred

ITO(Exemptions), Vadodara vs. Muslim Islahi Jamat, Vejalpur Road, Godhra

In the result, the appeal of the Revenue is dismissed

ITA 1854/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2016-17

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2016-17

For Appellant: NoneFor Respondent: Shri Prateek Sharma, Sr. D.R

Section 148Section 151(1)Section 69

Whether on the facts and circumstances of the case in law, the Ld.CIT(A), NFAC is justified in quashing the assessment order when the specified authority under Section 151(1) has an extended time till 30 June 2021 to grant approval where the instant case pertains

Ramesh Purshottam Modi, Mumbai vs. Income Tax Officer Circle 22(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6577/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Purshottam Ito Circle 22(1) Modi Income Tax 303, Modi House, Linking Vs. Department, Road, Khar West, Piramal Chamber, Mumbai-400 052 Dr. Ss Rao Marg, Parel, Mumbai 0 400 012 Pan/Gir No. Aahpm2793F (Applicant) (Respondent) Assessee By Shri Ashwani Kumar A/W Ms. Deepali Aggarwal, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 12.02.2026 Date Of Pronouncement 19.02.2026

Section 143(3)Section 144BSection 147Section 148Section 250Section 94(7)Section 94(8)

argued that the order passed under section 148A(d), after considering the reply of the assessee and after obtaining approval from the specified authority, constitutes the final reasons for issuance of notice under section 148. Therefore, according to the learned DR, the reassessment proceedings were validly initiated in accordance with

Kanahiya Lal Politechnic, Roorkee vs. ITO, W-1(3)(2), Haridwar

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

ITA 86/DDN/2025[2016-17]Status: DisposedITAT Dehradun18 Feb 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2016-17] Kanahiya Lal Polytechnic Vs Nfac, Delhi/ Dehradun Road, Roorkee Ito, Aaykar Bhawan, Civil Uttarakhand-247667 Lines, Roorkee, Pan-Aabak4938M Uttarakhand--247667 Appellant Respondent Assessee By Shri Tilak Raj, Adv. Revenue By Shri Amar Pal Singh, Jcit Dr Date Of Hearing 09.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 07.03.2025 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2015-16/110417665 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 28.12.2023 Passed U/S 147 R.W.S. 144 R.W.S. 144B Of The Act Pertaining To Assessment Year 2016-17. 2. Brief Facts Of The Case Are That Case Of The Assessee Was Reopened By Issue Of Notice U/S 148 Of The Act On 22.03.2023, On The Basis Of Information Available With The Department That Assessee Has Deposited Cash Of Inr 1,39,81,145/- In Union Bank Of India During The Financial Year 2015-16. The Assessee Society Has Not Filed Its Return Of Income For The Year Under Consideration. Thereafter, Statutory Notices Were Issued From Time To Time To Provide The Assessee An Opportunity To Substantiate Its Claim By Submission Of Documentary Evidences. During The Course Of Assessment Proceedings, Despite Of Many Opportunities, Assessee Failed To File Any Reply Or Documentary Evidence To Substantiate Its Claim. In Absence Of Information & Documentary Evidence Filed By The Assessee, The Ao Assessed The Income Of The Assessee At Inr 1,86,27,053/- Vide Assessment Order Dated 28.12.2023 Passed U/S 147 R.W.S. 144 R.W.S. 144B Of The Act.

Section 10Section 144Section 144BSection 147Section 148Section 151Section 250

issued by FAO and JAO had no jurisdiction to issue notice u/s 148. 9. That the approval u/s 151 by the specified authority was granted mechanically without due application of mind and approval order is bereft of any reasons The JAO initiated proceedings without making proper inquiry whereas the assessee ... locally located. Also, wrong reasons were recorded and placed before the specified authority through prescribed format. 10. That the Laws settled that real income should be assessed with established source whereas the appellate authority only followed jurisdictional AO without going through the record. 11. That the appellant craves leave

Br Associates, Uttarakahand vs. ACIT, Rishikesh

In the result, the appeal of the assessee is allowed and the assessment order is quashed

ITA 175/DDN/2025[2016-17]Status: DisposedITAT Dehradun18 Feb 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2016-17] M/S. B R Associates Vs Acit Jolly Grant, Circle-1(4)(1) Bhaniyawala, Dehradun, Rishikesh, Uttarakhand-248140 Uttarakhand-249201 Pan-Aaqfb6241E Appellant Respondent Assessee By Shri Kanwal K.Juneja, Ca Revenue By Shri A.S.Rana, Sr.Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.07.2025 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Dehradun/10296/2018-19 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 28.12.2018 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Its Return Of Income On 08.10.2016 Declaring Total Income At Inr 46,02,250/-. The Case Was Selected For Scrutiny Under Cass & The Notice Was Issued By Ito, Ward-1(2), Dehradun Thereafter, The Case Was Transferred To Dcit, Circle-1(1)(1), Dehradun. Thereafter, Various Notices Were Issued & Replies Were Filed By The Assessee. After Considering The Submissions, Total Income Was Assessed At Inr 1,93,96,755/- By Making Addition Of Inr 55.00 Lakhs Towards Bogus Advances & Inr 14,13,600/- As Deemed Income & Further Disallowance Of Expenses Of Inr 78,80,905/- Was Made.

Section 142(1)Section 143(2)Section 143(3)Section 250Section 43C

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 obligated to have recorded his reasons for transferring the case from the aforesaid Dy. CIT, Circle-1, Bhilai

Hotel Selection Grand, Tadepalligudem vs. Income Tax Officer, Ward-1, Tadepalligudem

ITA 741/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2016-17

Bench: Shri Ravish Sood, Hon'Ble & Shri Omkareshwar Chidara, Hon'Bleआयकर अपीलसं./I.T.A.No.741/Viz/2025 (निर्धारण वर्ष / Assessment Year:2016-17) Hotel Selection Grand Gollagundam Centre K.N. Road Tadepalligudem-534101 Andhra Pradesh [Pan: Aakfh0778C] Vs. Income Tax Officer, Ward -1 Aayakar Bhavan, 2-1-56/1 Opp. Punjab National Bank K.N.Road, Tadepalligudem – 534101 Andhra Pradesh करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement Per Ravish Sood, Jm: : Shri I. Kama Sastry, Ca : Sri K.Prasad, Sr.Dr : 12.02.2026 : 18.02.2026 आदेश /Order The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 24.10.2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short "A.O”) Under Section 147 R.W.S. 144 Of The Income-Tax Act, 1961 (For Short, "The Act"), Dated 06.01.2025 For The Assessment Year 2016-17. The Assessee Firm Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us: "1. The Notice Under Section 148 Issued On 18.04.20232 For The

Section 115BSection 142ASection 147Section 148Section 148ASection 149(1)(b)Section 151ASection 234ASection 69A

entire reassessment proceedings are invalid and void ab initio. 6. The reopening of assessment is invalid as the copy of the approval of the specified authority is not furnished to the assessee till date though the same is mandated by the CDT guidelines for issue of notices under section

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

notice issued u/s 148 as well as the order passed u/s 148A(d) as bad in law for want of approval of the specified authority as provided in section 151(ii) of the I.T. Act. Page 7 of 74 ITA No 1894 of 2025 Exel Rubber Private ... carried out prior to or at the time of recording the satisfactions and reasons as well as while obtaining the requisite approvals of the specified authority. The Assessing Officer has not done this exercise before issuing notice u/s 148 of the Act, therefore, the same suffers from an inherent lack

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1884/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

Explanation (2) of section 148 of the Act for recording reasons. Further, the satisfaction recorded by the A.O should be forwarded to the specified authority for obtaining sanctions as per provisions of section 151 of the I.T. Act. Although the law is very clear in so far as the procedure ... searched person and the A.O needs to apply his mind and while seeking approval under section 151 of the Act from the specified authority, demonstrate that the information obtained/discovered during the search suggest that income has escaped, assessment under Explanation (2) is for the relevant A.Y for which notice under

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1876/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

notice issued u/s 148 as well as the order passed u/s 148A(d) as bad in law for want of approval of the specified authority as provided in section 151(ii) of the I.T. Act. 9. The learned Counsel for the assessee has pointed out that since the seized material ... carried out prior to or at the time of recording the satisfactions and reasons as well as while obtaining the requisite approvals of the specified authority. The Assessing Officer has not done this exercise before issuing notice u/s 148 of the Act, therefore, the same suffers from an inherent lack

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad.

In the result, all the six appeals i

ITA 1873/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

notice issued u/s 148 as well as the order passed u/s 148A(d) as bad in law for want of approval of the specified authority as provided in section 151 (ii) of the I.T. Act. 9. The learned Counsel for the assessee has pointed out that since the seized material ... carried out prior to or at the time of recording the satisfactions and reasons as well as while obtaining the requisite approvals of the specified authority. The Assessing Officer has not done this exercise before issuing notice u/s 148 of the Act, therefore, the same suffers from an inherent lack

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1571/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 132(4)Section 143(3)Section 148

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1566/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 132(4)Section 143(3)Section 148

Kamalapat Ratanchand Chopra, Mumbai vs. Dy. Commissioner of Income Tax, Circle-19(1), Mumbai

ITA 7880/MUM/2025[2013-14]Status: DisposedITAT Mumbai18 Feb 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawal

Section 10(38)Section 143(3)Section 147Section 148Section 148ASection 149(1)Section 151ASection 69C

section 148A, for the Assessing Officer to comply with, mentions that 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 ... assessee with the prior approval of the specified authority. iii. He shall consider the reply of the assessee furnished, if any in response to the show cause notice. iv. He shall decide on the basis of material available on record and after considering the reply of the assessee

Harleen Kaur Ghura, Mumbai vs. ITO Ward 28(1)(1), Mumbai

In the result appeal filed by the assessee is allowed

ITA 7664/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarharleen Kaur Ghura Vs. Ito, Ward 28(1)(1), B 602 Ambe Prerna, Sector Mumbai 3, Ghansoli, It-Office, Vasi Railway Navi Mumbai- 400701, Station Building, Navi Mumbai - 400703 Pan/Gir No. Aovpg9346L (Applicant) (Respondent)

Section 148Section 148ASection 151Section 151ASection 250Section 69

148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-27 Mumbai which was not the correct 'specified authority' as per Section 151 who should have approved it when three years have already elapsed from the end of the relevant assessment year

Annai Amali Meenbedi Tholilar Moonata Sangam, Tiruchendur vs. Income Tax Officer, Ward 1, Tuticorin

ITA 2957/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No. 2956 & 2957/Chny/2025 िनधा"रण वष" /Assessment Year: 2015-16 & 2018-19

For Appellant: Mr. R Venkata Raman, CAFor Respondent: Ms. R Anitha, Addl, CIT

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

provisions of Section 151 defines the sanctioning authority and the relevant provisions as it stood at that point in time reads as under: “151. Specified authority for the purposes of section 148 and section 148A be,— (i) Principal Commissioner or Principal Director or Commissioner or Director, if three years ... escaped assessment in the case of the assessee for the relevant assessment year and the Assessing Officer has obtained prior approval of the specified authority to issue such notice.” Thus, on the facts of the present case, the Show Cause Notice u/s.148A(b) of the Act was issued upon

Annai Amali Meenbedi Tholilar Moonata Sangam, Tiruchendur vs. Income Tax Officer, Ward 1, Tuticorin

ITA 2956/CHNY/2025[2015-16]Status: DisposedITAT Chennai17 Feb 2026AY 2015-16

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No. 2956 & 2957/Chny/2025 िनधा"रण वष" /Assessment Year: 2015-16 & 2018-19

For Appellant: Mr. R Venkata Raman, CAFor Respondent: Ms. R Anitha, Addl, CIT

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

Aman Gupta, Chennai vs. Deputy Commissioner of Income Tax, Circle - 1, Ltu Chennai, Chennai

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

ITA 2565/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Feb 2026AY 2016-17

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2565/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Shri Aman Gupta, The Deputy Commissioner A-1, Vrindavan Enclave, Vs. Of Income Tax, 189, Lloyds Road, Circle 1, Gopalapuram, Ltu, Chennai – 600 086. Chennai. Pan: Adzpa 0417D (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri V. Tharish, Ca ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 17.02.2026

For Appellant: Shri V. Tharish, CAFor Respondent: Ms. Gouthami Manivasagam

Section 147ASection 148Section 148ASection 250Section 69A

required for issuing notice under :- 9 -: section 148 where the order under section 148A(d) has been passed with the prior approval of the specified authority. In the present case, the order under section 148A(d) itself was passed with the prior approval of the Pr. CIT (as evident from ... beyond the period of 3 years from end of the relevant assessment year and obtained prior approval from the PCIT who is not a specified authority u/s.151(ii) of the Act. The notice issued u/s.148 of the Act reads as follows:- “1 I have information in your case under