“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

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

Bijay Kumar Garodia, Kolkata vs. DCIT, Central Circle 3(4), Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2938/KOL/2025[2013-2014]Status: DisposedITAT Kolkata05 Mar 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132Section 132(1)Section 143(3)Section 250Section 271A

account or other documents maintained in the normal course relating to such previous year; or (B) otherwise not been disclosed to the [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] Commissioner before the date of search; or (ii) any income of the specified previous year represented, either wholly

Gopal Anil Kumar, Bangalore vs. DCIT, Central Circle-1(3), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 862/BANG/2025[2018-19]Status: DisposedITAT Bangalore05 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Ms. Pooja Maru, A.RFor Respondent: Sri Balusamy N., D.R

Section 132Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 37Section 44ASection 68

reopening of assessment especially previously framed after scrutiny. This additional safe guard not only involves the application of mind on the part of the Chief Commissioner or the Commissioner whose satisfaction, should be based on the reasons recorded by the Assessing Officer, and such satisfaction should be that

Jignesh Natverlal Patel (Represnted by Late Natverlal Nanubhai Patel), Mumbai vs. ITO Ward 24(3)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 6769/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Mar 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawaljignesh Natverlal Patel Vs Ito Ward-24(3)(1), Mumbai (Represented By Late Piramal Chamber, Lalbaug, Natverlal Nanubhai Patel) Mumbai-400012 401 Adarsh Building, Rto Four Bunglows, Andheri (West), Mumbai-400053 Pan:Aaapp1767B Appellant Respondent

For Appellant: Shri Aditya RamchandranFor Respondent: Shri Sushil B. Shende (Sr DR)

Section 139(1)Section 147rSection 148Section 148ASection 149Section 151Section 151ASection 250

more than three years have elapsed from the end of the relevant assessment year, the specified authority, who can grant sanction is the Principal Chief Commissioner or Principal Director General or where no Principal Chief Commissioner or Principal Director General is available then Chief Commissioner or Director General of Income ... authority specified under section 151(ii) of the 8 Jignesh Natverlal Patel (Represented by Late Natverlal Nanubhai Patel) Act, namely the Principal Chief Commissioner or Chief Commissioner, and that the proviso inserted by the Finance Act, 2023 has no retrospective application. In the present case, it is undisputed that

Srinivasa Rao Sirivuri Proprietor, Vizianagaram vs. Income Tax Officer, Vizianagaram

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

ITA 459/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam04 Mar 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 44ASection 69A

following decisions rendered by the Apex Court in Union of India v. Rajiv Bansal; High Court of Delhi in Sheetal international (P) Ltd v. Chief Commissioner of Income-tax, Central-2z; High Court of Karnataka at Bengaluru in Tarish Investment and Trading Company (P) Ltd., v. Union of India3; High

Late Abdullah Abdulmajeed, Rep. by L/H, Pudukkottai vs. ITO, Ward-1, Pudukkottai

ITA 3294/CHNY/2025[2015-16]Status: DisposedITAT Chennai04 Mar 2026AY 2015-16

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

issued a notice u/s. 148A(b) of the Act on 25.03.2022. The said notice was issued with the prior approval of the Principal Chief Commissioner of Income Tax, Tamil Nadu & Puducherry, proposing initiation of reassessment proceedings u/s. 147 on the ground that income chargeable to tax had allegedly escaped assessment

Veerakeralam Pacb, Coimbatore vs. ITO, Ncw 4(1), Coimbatore

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

ITA 3291/CHNY/2025[2019-20]Status: DisposedITAT Chennai04 Mar 2026AY 2019-20

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No. 3291/Chny/2025 "नधा#रण वष# /Assessment Year: 2019-20

For Respondent: 11.02.2026

Section 10ASection 139(1)Section 139(4)Section 143(1)Section 143(1)(a)Section 250Section 80ASection 80P

adjudication on merits. 9. The ld. Counsel for appellant society submitted that the delay for filing the return of income was condoned by ld. Chief Commissioner of Income Tax, Coimbatore in exercise of the powers vested with him u/s 119(2)(b) of the Income Tax Act vide order dated ... matter to the file of Assessing Officer/ CPC to pass a rectification order in the light of the impugned order passed by the Chief Commissioner of Income Tax condoning the delay in filing the return of income. 10. On other hand, ld. Sr. DR has no serious objection to remand

Govindan Gnanavel, Nagapattinam vs. ITO, Ward-1(1), Trichy

In the result, the appeal of the assessee is allowed

ITA 3202/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.3202/Chny/2025 िनधा"रण वष" /Assessment Year: 2018-19

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Aswathy, JCIT

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

years and therefore as per the provisions of Section 151 of the Act, the AO should have obtained the approval from Principle Chief Commissioner of Income Tax (PCCIT). The Ld. AR further submitted that in the present case the AO has obtained approval from Principle Commissioner of Income Tax (PCIT ... 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

Ramachandran Meenakshi, Chennai vs. Income Tax Officer, Non Corporate Ward 22(1), Tambaram

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

ITA 3182/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy S

For Appellant: Mr.R. Venkata Raman, C.AFor Respondent: Dr. M.D.Vijay Kumar, JCIT

Section 148Section 148ASection 151

three year, therefore, approval was required to be taken as per provisions of the amended section 151 of the Act from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General of Income tax and not from the Principal Commissioner of Income Tax as held ... relevant assessment year, the specified authority as per sub clause (ii) of section 151, to sanction issue of notice u/s 148, was the Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, then, Chief Commissioner or Director General. Since grant

S 1284 Thathaiyangarpatty Paccs Ltd., Namakkal vs. ITO, Ward-2, Namakkal

ITA 3172/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.3171 & 3172/Chny/2025 िनधा"रण वष" /Assessment Years: 2017-18 & 2018-19 S 1284 Thathaiyangarpatty Primary The Income Tax Officer, Agricultural Co-Operative Credit Vs. Ward-2, Society Ltd., Namakkal. Karaikuruchipudur P.O., Namakkal – 637 018. Pan: Aagas 9153H

For Appellant: Mr. A. Tamilamudan, C.A ,-For Respondent: Ms. Aswathy, JCIT

Section 139(1)Section 147Section 148Section 148ASection 151Section 250Section 69ASection 80P

years and therefore as per the provisions of Section 151 of the Act, the AO should have obtained the approval from Principle Chief Commissioner of Income Tax (PCCIT). The ld AR further submitted that in the present case the AO has obtained approval from Principle Commissioner of Income Tax (PCIT ... 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

S 1284, Thathaiyangarpatty Paccs Ltd., Namakkal vs. ITO, Ward-2, Namakkal

ITA 3171/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Mar 2026AY 2017-18

For Appellant: Mr. A. Tamilamudan, C.A ,-For Respondent: Ms. Aswathy, JCIT

Section 139(1)Section 147Section 148Section 148ASection 151Section 250Section 69ASection 80P

Mm 289 Thondamanginam Primary Agri Co-Op Credit Society, Karur vs. Income Tax Oficer, Karur

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

ITA 2880/CHNY/2025[2020-21]Status: DisposedITAT Chennai04 Mar 2026AY 2020-21

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.2880/Chny/2025 िनधा#रण वष# /Assessment Year: 2020-21

For Appellant: NoneFor Respondent: Ms. R. Anitha, Addl. CIT

Section 139(1)Section 148Section 250Section 80ASection 80PSection 80P(2)(d)

Departmental Representative. 4. The assessee has made a written submission on 25.02.2026 wherein it is stated that the assessee filed a petition before Chief Commissioner of Income Tax seeking condonation of delay in filing the return of income which was rejected by the CCIT. It is further submitted that

Shri K.P. Magennavar Laxmi Credit Souharda Sahakari Sangh Ltd.Manjari., Chikodi vs. Income Tax Officer, Ward-1, Nippani

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

ITA 33/PAN/2026[2015-2016]Status: DisposedITAT Panaji27 Feb 2026AY 2015-2016

Bench: Shri Pavan Kumar Gadalei T A. No.33/Pan/2026 (A.Y. 2015-16 ) Shri K.P.Magennavar Laxmi Vs I.T.O-Ward-1, Credit Souharda Sahakari Nemchand Building, . Sangh Limited, 747,Ashoknagar, 521,Laxmibuilding,Mainroad, Nipani-591237, Manjari, Chikodi, Karnataka. Belagavi-591213, Karnataka. Pan .No. Aabas3175N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Jaykumar Patil.Ar Revenue By Smt.Thamba Mahendra.Sr.Dr सुनवाई की तारीख/Date Of Hearing 25.02.2026 घोषणा की तारीख/Date Of Pronouncement 27.02.2026 Order Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of Addl/Jcit(A)-7 Mumbai Passed U/Se 143(3) & U/Sec250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Ac & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act On Interest Income From Cooperative Banks & Scheduled Banks. 2. The Brief Facts Of The Case Are That, The Assessee Souhard Credit Cooperative Society Is Engaged In Providing

Section 80P(2)(a)Section 80P(2)(d)

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

Stp Enterprises, Tirunelveli vs. DCIT, Circle-1, Tirunelveli

The appeal of the assessee is allowed

ITA 3729/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3729/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT

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

years and therefore, as per the provisions of Section 151 of the Act, the AO should have obtained the approval from Principle Chief Commissioner of Income Tax (PCCIT). The Ld AR further submitted that in the present case the AO has obtained approval from Principle Commissioner of Income Tax (PCIT ... 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

Jayantika Jatia, Kolkata vs. DCIT, Circle 29, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2250/KOL/2025[2016-2017]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Jayantika Jatia Dcit, Circle 29, Shree Gunjan, 7, Ronaldshay Aaykar Bhawan Dakshin,2, Road, Kolkata-700027, West Gariahat Road(South), Kolkata- Vs. Bengal 700031, West Bengal (Appellant) (Respondent) Pan No. Akwpm8544K Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Sandip Sarkar, Dr Date Of Hearing: 27.01.2026 Date Of Pronouncement: 26.02.2026

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Sandip Sarkar, DR

Section 144BSection 147Section 148Section 148ASection 151

provided that with effect from 01.04.2023, the specified authority for the purpose of section 148 and 148A of the Act shall be Pr. Chief Commissioner of Income Tax, if more than three years have lapsed from the end of the relevant assessment year.In the present case, the ld. AR submitted ... find that the competent authority to sanction the issuance of notice u/s 148 of the Act is the Pr. Chief Commissioner of Income Tax, if more than three years have elapsed after the end of the relevant assessment year. In the present case, the notice

DCIT, Central Circle-4(3), Kolkata vs. Brgd Sponge & Iron Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed and the appeal

ITA 1966/KOL/2025[2016-17]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-17

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

Section 115JSection 132(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 68

affidavits before the Metropolitan Magistrate 12.4. Even the CBDT Letter No.286/2/2003-IT(Inv) dated Oct 3, 2003 in this respect read as under: "To The Chief Commissioners of Income Tax, (Cadre Contra) & All Directors General of Income Tax Inv. Page | 13 ITA Nos. 1966& 1433/KOL/2025 BRGD Sponge & Iron

Brgd Sponge & Iron Pvt. Ltd., Kolkata vs. DCIT, Central Circle 4(3), Kolkata

ITA 1403/KOL/2025[2016-2017]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-2017

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

Section 115JSection 132(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRIPRADIP KUMAR CHOUBEY, JM ITA

Bajranglal Bhawarlal Sharma, Borivali East vs. Income Tax Officer, Kautilya Bhavan

ITA 285/MUM/2026[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh SalujaFor Respondent: Shri Aditya Rai

Section 143(3)Section 144BSection 147Section 148Section 148ASection 50CSection 50C(2)

regime) was issued after the expiry of 3 years from the end of the relevant assessment year, approval of the higher authority - Principal Chief Commissioner of Income Tax should have been obtained under Section 151(ii) of the Act. The stand taken by the Revenue is that the notice originally ... facts and circumstances of the present case the issue that arises for consideration is whether 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

Sapna Umesh Dutta, Mumbai vs. ITO Ward, 41(2)(5), Mumbai

ITA 263/MUM/2026[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: passing Order, under Section 148A(d) of the Act and issuing notice dated 31/07/2022, the Assessing Officer obtained approval/sanction from the Principal Commissioner of Income Tax, Mumbai. The reassessment proceedings culminated into passing of the Assessment Order, dated 23/05/2023, under Section 147 of the Act. The appeal preferred by the Assessee against the aforesaid Assessment Order was dismissed by the CIT(A) vide Order, dated 27/11/2025. Being aggrieved, the Assessee has preferred th

For Appellant: Shri Tanmay PhadkeFor Respondent: Shri Aditya Rai

Section 147Section 148Section 148ASection 151Section 151A

ITO 13(2)(1), Mumbai vs. Ska Sales Private Limited, Mumbai

ITA 5967/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Prakash Jhunjhunwala &For Respondent: Shri Nakul Agrawal

Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

Principal Directoror Commissioner or Director if three years or less have elapsed from the end of the relevant assessment year; and (ii) Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General if more than three years have elapsed from the end of the relevant assessment year

Ska Sales Pvt Ltd, Mumbai vs. Income Tax Officsr, Ward 13(2)(1), Mumbai

ITA 5527/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C