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“Chief Commissioner”

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
98
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
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.

Mohinder Singh Gill v. Chief Election Commissioner
1 SCC 405 · 1978 · Supreme Court
79
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
54
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
50
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
47
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
37
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

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 3045/CHNY/2025[2014-15]Status: DisposedITAT Chennai26 Dec 2025AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Mr. R. Venkataraman, CA &For Respondent: Shri. ARV Sreenivasan, CIT
Section 142(1)Section 144Section 147Section 148Section 148ASection 151ASection 69Section 69A

years, sanction in terms of section 151 of the Act, as applicable on the relevant date, was required to be obtained from the Principal Chief Commissioner / Principal Director General / Chief Commissioner / Director General, as the case may be. However, a perusal of the notice issued u/s.148 of the Act reveals

Kinkini, Bhilwara vs. ITO Exemption Ward 1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1185/JPR/2025[2023-24]Status: DisposedITAT Jaipur24 Dec 2025AY 2023-24

Bench: SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Sh.Mahendra Gargieya, AdvocateFor Respondent: Sh. Gautam Singh Choudhary
Section 11Section 11(1)Section 12ASection 143Section 143(1)Section 143(1)(a)Section 234BSection 250

rejected only on the technical grounds. 7.2 This Court in several recent decisions, namely in the case of Royal Led Equipments (P.) Ltd. v. Chief Commissioner of Income-tax [2025] 174 taxmann.com 61 (Gujarat)/Special Civil Application No. 14786 of 2024 and in the case of Surat Smart City Development

Somireddy Sudhakar Reddy, Ibrahimpatnam vs. ITO., Ward-9(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1505/HYD/2025[2017-18]Status: DisposedITAT Hyderabad24 Dec 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1505/Hyd/2025 Assessment Year 2017-2018 Somireddy Sudhakar The Income Tax Officer, Reddy, Ibrahimpatnam Vs. Ward-9(1), Pin -501 506. R R Dist. Hyderabad. Pan Bghps3108R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Mohd. Afzal, Advocate राज" व "ारा /Revenue By: Sri Abhinav Pittal, Sr. Ar

For Appellant: Sri Mohd. Afzal, AdvocateFor Respondent: Sri Abhinav Pittal, Sr. AR
Section 269SSection 269TSection 271DSection 274

Deputy Commissioner (Appeals) or] the Commissioner (Appeals) or, as the 9 ITA.No.1505/Hyd./2025 case may be, the Appellate Tribunal is received by the Chief Commissioner or Commissioner, whichever period expires later; [Provided that in a case where the relevant assessment or other order is the subject-matter ... within one year from the end of the financial year in which the order of the Commissioner (Appeals) is received by the "[Principal Chief Commissioner or] Chief Commissioner or "[Principal Commissioner or] Commissioner, whichever is later. (b) n a case where the relevant assessment or other order is the subject

Thulasi Chamarthy, Chittoor vs. Income Tax Officer, Ward - 1, Chittoor

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

ITA 1374/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19
Section 147Section 148Section 148ASection 151Section 250Section 54Section 54F

facts and in the circumstances of the case, the notice issued U/s. 148 of the Act on 07.04.2022 without prior approval of the Pr. Chief Commissioner of Income Tax being the appropriate authority in terms of section 151(ii) of the Act is invalid." 3. As the assessee by raising ... Commissioner or Director, if three years or less than three years have elapsed from the end of the relevant assessment year; (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three

Sindhumati Ramavtar Pathak, Borivali Mumbai vs. Asst Commissioner of Income Tax 32 3 Mumbai Presently Dy C I T Circle 42 3 1 Mumbai, Mumbai

In the result, Assessee’s appeal is allowed

ITA 4914/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Dec 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Prabhash Shankar (Am) Sindhumati Ramavtar Pathak Acit-32(3) 4, Shree Bhalchandra Kripa Presently Cit, Circle Building, Daulat Nagar Road Vs. 42(3)(1) No. 3, Borivali East Kautilya Bhavan Bkc, Mumbai-400 066. Mumbai-51. Pan : Agbpp5972D Appellant Respondent

For Appellant: Shri Jitendra Singh, Ld. ADVFor Respondent: Ms. Kavitha Kaushik, Ld. DR
Section 10(38)Section 250Section 68Section 69C

Vinod Premjibhai Gangani (2025) 178 taxmann.com 269 (Gujarat) (vi) Pr. CIT Vs. Divyaben Prafulchandra Parmar (2024) 169 taxmann.com 473 (Gujarat) (vii) Chief Commissioner of Income Tax (OSD) Vs. Nilesh Jain (HUF) (2024) 163 taxmann.com 229(Madhya Pradesh) (viii) Pr. CIT Vs. Ritu Agarwal Shreeram (2023) 453 ITR 520 (Rajasthan

Punya Sthali Tirth Trust, Uttar Pradesh vs. ITO Ward (Exemption) Ward 2(4), Delhi

Appeal is allowed

ITA 5713/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Punya Sthali Tirth Trust, Vs. Income Tax Officer, Gang Nahar Road, Ward (Exemption) - 2(4), Muradnagar, Delhi Uttar Pradesh Pan: Aabtp8479P (Appellant) (Respondent)

Section 13ASection 147Section 148Section 148ASection 151Section 29A

necessary approval from the Commissioner of Income Tax (Exemption), Delhi than the prescribed authority under section 151(ii) of the Act i.e. Principal Chief Commissioner or……………………., if more than three years have elapsed from the end of the relevant previous year. This clinching factual position has gone unrebutted from ... relevant assessment year, thus, in terms of Section 151(ii) of the Act, the same was required to be approved by the 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

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, both appeals of the assessee are allowed

ITA 5114/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 68

compliance of the Hon’ble Supreme Court order in the case of Ashish Aggarwal (supra), the sanctioning Authorities should have been Pr. Chief Commissioner or Pr. Director General or the Chief Commissioner but in this case the approval has been obtained from the Pr. Commissioner of Income Tax which ... decided while quashing the notices issued u/s 148 of the Act as the permission was granted only by Pr. Commissioner and not by Pr. Chief Commissioner. Hisar Leading Bank Co-op Non-agri Thrift & Credit Society 9. The Ld. Departmental Representative (in short ‘DR’) on the other hand simply relied

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, both appeals of the assessee are allowed

ITA 5113/DEL/2025[2016-17]Status: DisposedITAT Delhi24 Dec 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 68

compliance of the Hon’ble Supreme Court order in the case of Ashish Aggarwal (supra), the sanctioning Authorities should have been Pr. Chief Commissioner or Pr. Director General or the Chief Commissioner but in this case the approval has been obtained from the Pr. Commissioner of Income Tax which ... decided while quashing the notices issued u/s 148 of the Act as the permission was granted only by Pr. Commissioner and not by Pr. Chief Commissioner. Hisar Leading Bank Co-op Non-agri Thrift & Credit Society 9. The Ld. Departmental Representative (in short ‘DR’) on the other hand simply relied

Toyota Boshoku Corporation, Japan vs. Assistant Commissioner of Income Tax Circle 3(1)(1) International Taxation New Delhi, New Delhi

In the result, both the appeals of the Assessee are allowed

ITA 2463/DEL/2024[2017-2018]Status: DisposedITAT Delhi24 Dec 2025AY 2017-2018

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri Kashish Gupta, CA
Section 143(3)Section 144C(5)Section 148Section 148ASection 151

expiry of 3 years from the end of the relevant assessment year. Hence, the competent authority to approve the reopening is Learned Principal Chief Commissioner of Income Tax (PCCIT) as per the amended provisions of section 151 of the Act. In the instant case, the approval has been obtained from ... relevant assessment year, thus, in terms of Section 151(ii) of the Act, the same was required to be approved by the Principal Chief Commissioner or Principal Director General or where there is no such authority, by Chief ITA Nos. 2462 & 2463/Del/2024 Toyota Boshoku Corporation Commissioner or Director General

Toyota Boshoku Corporation, Japan vs. Assistant Commissioner of Income Tax Circle 3(1)(1) International Taxation New Delhi, New Delhi

In the result, both the appeals of the Assessee are allowed

ITA 2462/DEL/2024[2016-2017]Status: DisposedITAT Delhi24 Dec 2025AY 2016-2017

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri Kashish Gupta, CA
Section 143(3)Section 144C(5)Section 148Section 148ASection 151

expiry of 3 years from the end of the relevant assessment year. Hence, the competent authority to approve the reopening is Learned Principal Chief Commissioner of Income Tax (PCCIT) as per the amended provisions of section 151 of the Act. In the instant case, the approval has been obtained from ... relevant assessment year, thus, in terms of Section 151(ii) of the Act, the same was required to be approved by the Principal Chief Commissioner or Principal Director General or where there is no such authority, by Chief ITA Nos. 2462 & 2463/Del/2024 Toyota Boshoku Corporation Commissioner or Director General

The Shiroda Progressive Urban Multipurpose Cooperative Society Limited, Ponda vs. Income Tax Officer, Panaji

In the result, the two appeals filed by the assessee are allowed for statistical purposes

ITA 273/PAN/2025[2020-21]Status: DisposedITAT Panaji23 Dec 2025AY 2020-21

Bench: Shri Pavan Kumar Gadalei T A. Nos.272 & 273/Pan/2025 (A.Y. 2018-19 & 2020-21 ) The Shiroda Progressive Urban Vs I T O, Multipurpose Cooperative National E Assessment . Society Limited, Centre, Shop.No.4, Opp: Police Station, Delhi. Shiroda Bhat, Ponda-403103.Goa Pan .No. Aabat7206P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT

The Shiroda Progressive Urban Multipurpose Cooperative Society Limited, Ponda vs. Income Tax Officer, Panaji

In the result, the two appeals filed by the assessee are allowed for statistical purposes

ITA 272/PAN/2025[2018-19]Status: DisposedITAT Panaji23 Dec 2025AY 2018-19

Bench: Shri Pavan Kumar Gadalei T A. Nos.272 & 273/Pan/2025 (A.Y. 2018-19 & 2020-21 ) The Shiroda Progressive Urban Vs I T O, Multipurpose Cooperative National E Assessment . Society Limited, Centre, Shop.No.4, Opp: Police Station, Delhi. Shiroda Bhat, Ponda-403103.Goa Pan .No. Aabat7206P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

Guttigedarara Credit Co-operative Society Ltd v ITO Ward 2(2), Mysore 377 ITR 464 (Kar) . 4. Vavveru Co-operative Rural Bank Ltd v Chief Commissioner of Income Tax 396 ITR 371 (A.P and Telangana). 5. Pr.CIT v Sahyadri Co-operative Credit Society Ltd 166 taxmann.com 445 (Ker). 6. Pr.CIT

Dearhood Foundation, Belagavi vs. The Deputy Director of Income Tax, CPC, Bengaluru

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 202/PAN/2025[2022-23]Status: DisposedITAT Panaji23 Dec 2025AY 2022-23

Bench: Shri Pavan Kumar Gadalei T A. No.202/Pan/2025 (A.Y.2022-23 ) Dear Hood Foundation, Ddit, Vs. Plot.No.1/S,Kanbargi Cpc, Industrial Area, Bengaluru-560500. Kanabargi.S.O, Karnataka. Belgaum-590015, Karnataka. Pan/Gir No. Aaicd1005D (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By Shri.Pramod Y Vaidya.Ar Revenue By Shri.Sanket Deshmukh.Sr.Dr सुनवाई की तारीख/Date Of Hearing 23.12.2025 घोषणा की तारीख/Date Of Pronouncement 23.12.2025 Order Per Pavan Kumar Gadale, Jm:

Section 11Section 119(2)(b)Section 8

find that the assessee has submitted a request for condonation of delay regarding the filling of Form.No.10B of the Act before the Chief Commissioner of Income Tax (Exemption) Bengaluru and the assessee has 3 DearHood Foundation. failed to produce any evidence regarding the delay has been condoned. Therefore

Gamnaram Okhaji Prajapati, Mumbai vs. DCIT. Circle 1(2)(1), Mumbai

Appeal is allowed

ITA 6791/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Dec 2025AY 2016-17

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh ShahFor Respondent: Shri Swapnil Choudhary
Section 115BSection 144Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 153CSection 234A

ambit of provisions of Section 151(ii) of the Act whereby the specified authority for grant of approval has been specified as Principal Chief Commissioner of Principal Director General or Chief Commissioner of Director General. Contrary to the aforesaid requirement, the approval in the present case has been obtained from ... issue that arises for consideration is whether in terms of Section 151 of the Act the Principal Commissioner of Income Tax; or the Principal Chief Commissioner of Income Tax was the Specified Authority for seeking approval for passing order under Section 148A(d) of the Act and issuance of notice

Shantilal Narottamdas Panchal, Malad East vs. ITO-41(3)(4), Mumbai, Bandra Kurla Complex

Appeal is allowed

ITA 3570/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18

Bench: Him.

For Appellant: Shri Ravindra PoojaryFor Respondent: Shri Bhagirath Ramawat
Section 144BSection 147Section 148Section 148ASection 151Section 56(2)(vii)

ambit of provisions of Section 151(ii) of the Act whereby the specified authority for grant of approval has been specified as Principal Chief Commissioner of Principal Director General or Chief Commissioner of Director General. Contrary to the aforesaid requirement, the approval in the present case has been obtained from ... issue that arises for consideration is whether in terms of Section 151 of the Act the Principal Commissioner of Income Tax; or the Principal Chief Commissioner of Income Tax was the Specified Authority for seeking approval for passing order under Section 148A(d) of the Act and 12 Assessment Year

Dy.CIT Cent. Cir -6(2), Mumbai vs. Shri Ashok B. Jiwarjka, Mumbai

In the result, the appeals filed by the revenue are hereby dismissed and the cross

ITA 2355/MUM/2021[2012-13]Status: DisposedITAT Mumbai23 Dec 2025AY 2012-13

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am

For Appellant: Shri. Bharat KumarFor Respondent: Shri. Surendra Mohan (SR-DR)
Section 132(1)Section 250Section 68Section 69C

undisclosed income. For the sake of convenience and clarity, the relevant instructions dated 10.3.2003 issued by CBDT is reproduced hereunder:- To All Chief Commissioners of Income tax (Cadre Contra) & All Directors General of Income Tax Inv. Sir, Sub:- Confession of additional Income during the course of search & seizure and survey

Dy.C.I, T. Cent. Cir -6(2), Mumbai vs. Shri Ashok B. Jiwrajka, Mumbai

In the result, the appeals filed by the revenue are hereby dismissed and the cross

ITA 2353/MUM/2021[2014-15]Status: DisposedITAT Mumbai23 Dec 2025AY 2014-15

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am

For Appellant: Shri. Bharat KumarFor Respondent: Shri. Surendra Mohan (SR-DR)
Section 132(1)Section 250Section 68Section 69C

undisclosed income. For the sake of convenience and clarity, the relevant instructions dated 10.3.2003 issued by CBDT is reproduced hereunder:- To All Chief Commissioners of Income tax (Cadre Contra) & All Directors General of Income Tax Inv. Sir, Sub:- Confession of additional Income during the course of search & seizure and survey

Dy.C.I.T. Cent. Cir -6(2), Mumbai vs. Shri Ashok B.Jiwrajka, Mumbai

In the result, the appeals filed by the revenue are hereby dismissed and the cross

ITA 2352/MUM/2021[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am

For Appellant: Shri. Bharat KumarFor Respondent: Shri. Surendra Mohan (SR-DR)
Section 132(1)Section 250Section 68Section 69C

undisclosed income. For the sake of convenience and clarity, the relevant instructions dated 10.3.2003 issued by CBDT is reproduced hereunder:- To All Chief Commissioners of Income tax (Cadre Contra) & All Directors General of Income Tax Inv. Sir, Sub:- Confession of additional Income during the course of search & seizure and survey

Dy C.I.T. Cent Cir -6(2), `Mumbai vs. Shri Ashok B. Jiwrajka, Mumbai

In the result, the appeals filed by the revenue are hereby dismissed and the cross objections filed by the assessee are allowed

ITA 2351/MUM/2021[2015-16]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-16

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am

For Appellant: Shri. Bharat KumarFor Respondent: Shri. Surendra Mohan (SR-DR)
Section 132(1)Section 250Section 68Section 69C

undisclosed income. For the sake of convenience and clarity, the relevant instructions dated 10.3.2003 issued by CBDT is reproduced hereunder:- To All Chief Commissioners of Income tax (Cadre Contra) & All Directors General of Income Tax Inv. Sir, Sub:- Confession of additional Income during the course of search & seizure and survey

Brij Bhushan Kalia, Up vs. ITO, Ward-61(1), Delhi

Appeal is allowed in above terms

ITA 7624/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Dec 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 7624/Del/2025 : Asstt. Year: 2017-18 Brij Bhushan Kalia, Vs Income Tax Officer, C/O Chaurasia & Associates, Ward-61(1), C-2302, Ats Advantage, New Delhi-110002 Indirapuram, Ghaziabad-201014 (Appellant) (Respondent) Pan No. Aaepk9068Q Assessee By: Sh. Venketesh Chaurasia, Adv. Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081596042(1) Dated 09.10.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Venketesh Chaurasia, AdvFor Respondent: Sh. Amit Shukla, Sr. DR
Section 13ASection 147Section 148Section 148ASection 29A

relevant assessment year, thus, in terms of Section 151(ii) of the Act, the same was required to be approved by the 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 ... Commissioner or Director, if three years or less than three years have elapsed from the end of the relevant assessment year; (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three