Which cases are most cited on Chief Commissioner?

Pvt Ltd. v. ACIT (93 Taxmann.com 296) — 98 citing judgments; Financial Services Pvt. Ltd. v. Dy. CIT (457 ITR 647) — 95 citing judgments; Ghanshyam K. Khabrani v. ACIT (346 ITR 443) — 89 citing judgments; Mohinder Singh Gill v. Chief Election Commissioner (1 SCC 405) — 79 citing judgments; Sahara India v. CIT & Others (216 CTR 303) — 54 citing judgments.

How many judgments discuss Chief Commissioner?

BharatTax indexes 2,876 ITAT, High Court and Supreme Court judgments that discuss Chief Commissioner (Section 2(15A) / Section 117).

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“Chief Commissioner”

Q: What is the leading case on Chief Commissioner?

Pvt Ltd. v. ACIT (93 Taxmann.com 296) is the decision most relied on for Chief Commissioner, cited in 98 judgments on BharatTax. Approval granted by the Principal Chief Commissioner or Principal Commissioner under Section 151 for reassessment proceedings under Section 148 must reflect due application of mind. A mere endorsement of "approved" without reasons or reference to material is insufficient, as the approval serves as a safeguard and must be meaningful, not ritualistic or formal.

Chapter I - PreliminarySection 2 - DefinitionsSection 2(15A) / Section 1172,876 judgments

The decision most relied on for Chief Commissioner is Pvt Ltd. v. ACIT (93 Taxmann.com 296), cited in 98 judgments on BharatTax.

Leading authorities on Chief Commissioner

Pvt Ltd. v. ACIT

93 Taxmann.com 296 · 2018 · High Court

citing judgments

Approval granted by the Principal Chief Commissioner or Principal Commissioner under Section 151 for reassessment proceedings under Section 148 must reflect due application of mind. A mere endorsement of "approved" without reasons or reference to material is insufficient, as the approval serves as a safeguard and must be meaningful, not ritualistic or formal.

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.

Mohinder Singh Gill v. Chief Election Commissioner

1 SCC 405 · 1978 · Supreme Court

citing judgments

When a statutory authority issues an order based on specific grounds, its validity must be assessed solely by those stated grounds and cannot be supported or improved by additional reasons provided later in affidavits or other means. An order that is invalid at its inception cannot be validated by subsequent justifications.

Sahara India v. CIT & Others

216 CTR 303 · 2008 · Reported

citing judgments

The requirement of prior approval from the Chief Commissioner or Commissioner under Section 142(2A) is a crucial safeguard against arbitrary assessment, placing a significant responsibility on the approving authority to ensure its genuine application and prevent it from becoming a mere formality.

New Noble Educational Society v. Chief Commissioner of Income Tax

448 ITR 594 · 2022 · Supreme Court

citing judgments

An institution qualifies as an 'educational institution' for tax exemption, including under Section 10(23C)(iiiab), only if it imparts structured, formal education, distinguishing it from general public utility activities under Section 2(15).

Star India Private Limited v. Chief Commissioner of Central Excise

280 ITR 321 · 2006 · Supreme Court

citing judgments

The Supreme Court holds that while the Legislature can enact laws retrospectively, this power does not normally extend to creating an offence or penal liability retroactively, nor to withdrawing a benefit already granted under a statute through retrospective amendment.

Oxford Academy for Career Development v. Chief CIT

315 ITR 382 · 2009 · High Court

citing judgments

The Commissioner of Income Tax (CIT) has no power to cancel registration granted under Section 12A of the Income Tax Act retrospectively, especially when there is no express provision in the Act for such cancellation and the order is quasi-judicial in nature.

Judgments citing Chief Commissioner

Rakesh Palepu, Devarakonda vs. Income Tax Officer, Ward-1, Nalgonda

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

ITA 448/HYD/2025[2018-19]Status: DisposedITAT Hyderabad21 Aug 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri B. Sri Harsha, C.AFor Respondent: Ms. P. Sumitha, SR-DR

Section 139Section 144Section 147Section 148Section 148ASection 151

relevant assessment year, in view of the provision contained under Section 151(ii) of the Act, the approval of the Principal Chief Commissioner or Chief Commissioner of Income Tax was required. Since such approval was obtained from PCIT instead of the Principal Chief Commissioner or Chief Commissioner of Income

S.S. Jain Sabha Golf Link, Ludhiana vs. CIT Exemptions, Jalandhar

ITA 482/ASR/2024[24-25]Status: DisposedITAT Amritsar20 Mar 2026

Bench: Dr. Dipak P. Ripote & Sh. Udayan Dasgupta

For Appellant: None

Section 12ASection 12A(1)(ac)

I.T.A. No. 482/Asr/2024 Assessment Year: N.A. 10) The appellants-case is similar to the above cited case laws wherein ITAT opined that the Ld. Chief commissioner has denied the approval not because he found the activities not genuine but for the reason that an event may occur in future benefitting

Vijay Kothari, Indore vs. DCIT (Central)-1, Indore

ITA 267/IND/2024[2015-16]Status: DisposedITAT Indore20 Mar 2026AY 2015-16

Bench: Shri B.M. Biyani

Section 143(3)Section 250

566/Ahd/2020 (ITAT, Ahmedabad) Cc) Shri Nilesh Jain (HUF) Vs. ITO-4(2), Indore - ITA No. 294/Ind/2020 (ITAT, Indore) d) The Chief Commissioner of Income-tax Vs. Shri Nilesh Jain (HUF) - ITA No. 56 of 2021 (Hon’ble MP High Court) 8. Ld. AR finally contended that the present case

Javitri Devi, Delhi vs. Income Tax Officer, Ward 30(5), Delhi

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

ITA 6619/DEL/2025[2016-17]Status: DisposedITAT Delhi20 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumara.Yr. : 2016-17 Javitri Devi, Vs. Income Tax Officer, R-7, Nehru Enclave, Ward 30(5), Kalkaji New Delhi New Delhi – 110 019 (Pan: Aafpd2491M) (Appellant) (Respondent)

For Appellant: Sh. S.C. Garg, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR

Section 13Section 148Section 148ASection 151

sought to be commenced after the lapse of three years from the end of the relevant A Y, undisputedly, it would be the Principal Chief Commissioner who would be liable to be recognised as being the competent authority. Viewed in that light, it is apparent that the reassessment action would ... issued u/s 148 of the Act is not a valid notice, as the approval was not granted by the specified authority i.e. Principal Chief Commissioner of Income Tax as mandated u/s 151(ii) We further observe that the impugned notice u/s 148 for AY 2017-18 was issued

Deputy Commissioner of Income Tax, Central Circle-20, Delhi, Jhandewalan vs. Krska Capital Private Limited, Delhi

In the result the appeal of the Revenue is dismissed and the cross objection of the Assessee is allowed

ITA 4666/DEL/2025[2016-17]Status: DisposedITAT Delhi18 Mar 2026AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2016-17

Section 132(4)Section 143(3)Section 147Section 148Section 68

three years approval was required to be obtained as per the amended provision of section 151(ii) of the Act from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General instead of Principal Commissioner of Income-tax-4 Delhi. (iii) Because the order appealed against ... assessment year, thus prior approval from the competent authority was needed but the competent authority in the case of assessee should have been Principal Chief Commissioner of Income Tax, whereas approval has been taken from the Principal Commissioner of Income Tax-4, Delhi. Respectfully following the decision

Amazon Smart Commerce Solutions Private Limited, Delhi vs. Principal Commissioner of Income Tax, Delhi-1, Delhi

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

ITA No. 3533/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT

Dindayal Agarwal, Berhampur vs. The Income Tax Officer, Ward-1, Berhampur.

In the result, the appeal of the assessee is allowed

ITA 471/CTK/2025[2017-18]Status: DisposedITAT Cuttack16 Mar 2026AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2016-17 Dindayal Agarwal Ito, Ward-1, Berhampur

For Appellant: Shri Pranaya Ku. Mishra, Prashant KumarFor Respondent: Shri Shakeer Ahamed, Sr. DR

Section 148Section 148ASection 151

invalid inasmuch as the sanction has been admittedly issued by the Principal Commissioner of Income Tax ("PCIT") and not by the Principal Chief Commissioner of Income Tax (PCCIT"). 2. Petitioner's request for a copy of the sanction has also been denied. Even in the affidavit in reply, the Department ... proceedings was granted by Commissioner after expiry of 3 years from end of relevant assessment year, said approval should have been granted by Principal Chief Commissioner, thus, impugned order passed under section 148A(d) of the Act and impugned notice issued under section 148 of the Act were

K 1364 Veerasolapuram Primary Agricultural Co Op Credit Society Limited, Tirupur vs. The Income Tax Officer, Ward 1(4) Tirupur, Tirupur

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

ITA 3790/CHNY/2025[2019-20]Status: DisposedITAT Chennai13 Mar 2026AY 2019-20

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3790/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 K 1364 Veerasolapuram Primary Vs. The Income Tax Officer, Agricultural Co Op Credit Society Ward 1(4), Limited, Veerasolapuram Po, Tirupur. Kangayam Tk. Tiruppur, Tamil Nadu, 638701. [Pan:Aabak4255B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. A. Vijayalakshmi, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 17.02.2026 घोषणा की तारीख /Date Of Pronouncement : 13.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.10.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For Assessment Year 2019-20. 2. At The Outset, It Was Submitted By The Ld Ar Ms. A. Vijayalakshmi, C.A. That The Authorities Below, Ignoring The Petition Filed By The Assessee

For Appellant: Ms. A. Vijayalakshmi, C.A. (virtual)For Respondent: Ms. Gouthami Manivasagam, Addl. CIT

Section 119(2)(b)Section 139Section 80P(2)(a)

order to get the deduction, the assessee filed a petition under section 119(2)(b) of the Act, before the Chief Commissioner of Income Tax (CCIT) which is still pending as is evident from Para No.4.5 of the assessment order. On perusal of the impugned order, it is clear

Gopi Kishan Makharia, Bhiwani vs. ITO-1, Bhiwani

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

ITA 8727/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklaassessment Year: 2017-18 Gopi Kishan Makharia, Vs Ito-1, Shree Saraswati Spinning Mills, Bhiwani, Birla Colony, Tosham Road, Haryana. Bhiwani, Haryana. Pan: Abhpm8102F (Appellant) (Respondent) Assessee By : Shri S.S. Nagar, Ca Revenue By : Shri Ravi Kant Chaudhary, Sr. Dr Date Of Hearing : 12.03.2026 Date Of Pronouncement : 13.03.2026 Order Per Madhumita Roy, Jm:

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Ravi Kant Chaudhary, Sr. DR

Section 147Section 148Section 148ASection 151Section 250

beyond three years from the date of expiry of the relevant assessment year ought to have been granted by the Pr. Chief Commissioner of Income Tax and in the instant case, since the same has been obtained from the Pr. Commissioner of Income Tax, the assessment proceedings is suffered ... three years from the end of the relevant assessment year, approval under Section 151(ii) is, therefore, required to be taken from the Principal Chief Commissioner of Income Tax or the Principal Director General of Income Tax or the Chief Commissioner of Income Tax and not the Principal Commissioner

Bmr Overseas Limited, Delhi vs. Deputy Commissioner of Income Tax Circle 4(2), C.R. Building Delhi 110002, Delhi

In the result the appeal of the assessee is allowed

ITA 6646/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Bmr Overseas Limited, Vs. Dcit, Circle 4(2), Zb-33/487, Plot No. 4 & 5, C.R. Building, Dilshad Garde New Delhi Industrial Area, Shahdara, Delhi – 110 095 [Pan No. Aafcb8509D) (Appellant) (Respondent)

Section 115BSection 143Section 147Section 148Section 151Section 156Section 157ASection 68

relevant assessment year. Accordingly, the sanctioning authority as per section 151(ii), should have been Principal Chie Commissioner or Principal Director General or Chief Commissioner or Director General. The said proposition was also clarified by the Hon’ble Apex Court in the case of UOI vs. Rajeev Bansal, Civil Appeal ... relevant assessment year, thus in terms of section 151(ii) of the Act the sanction was required to be approved by the Principal Chief Commissioner or Principal Director General or where there is no such authority, Chief Commissioner or Director General or Chief Commissioner, but in this case the approval

Vaneet Aggarwal, New Delhi vs. ACIT, Circle-14(2), New Delhi

In the result, appeal of the Assessee is dismissed

ITA 2607/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 10(38)Section 143(1)Section 143(2)Section 69ASection 69C

section 10(38), Assessing Officer could not question genuneness of those shares or treat them as bogus to make an addition under section 68. Chief Commissioner of Income-tax (OSD) v. Nilesh Jain (HUF) (2024) 163 taxmann.com 229 (MP) 4) Where assessee had produced all relevant documentary evidence to establish