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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

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

notice was issued on 25.07.2022, which is beyond the period of three years. So admittedly, the approval has to be obtained from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General as defined under Section 151(ii). But, in the present case, the approval ... that the sanction ought to have been obtained from the authorities empowered u/s.151(ii) of the Act of the new regime i.e. Principal Chief Commissioner or Principal Director General or Chief Commissioner of Director General of Income Tax. 37. In the instant case, admittedly the AO for issue of notice

ACIT22(1), Mumbai vs. Spr Associates, Mumbai

In the result, the appeal filed by the revenue stands dismissed and the cross-objection filed by assessee stands allowed

ITA 6562/MUM/2025[2018]Status: DisposedITAT Mumbai17 Feb 2026

Bench: Smt. Beena Pillai () & Shri Arun Khodpia, ()

Section 147Section 148Section 148ASection 68

approve the issuance of notice u/s 148 of the new regime, as per section 151 of the Act, would be the Principal Chief Commissioner of Income Tax or the Chief Commissioner of Income Tax. The Ld. AR placed reliance on the decision of the Hon’ble Supreme Court ... after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. 75. After 1 April 2021, the new regime has specified different authorities for granting sanctions under

Shri Hanuman Credit Souharda Sahakari Sangh Ltd, Belagavi vs. Income Tax Officer, Ward - 1, Nippani

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

ITA 235/PAN/2025[2017-18]Status: DisposedITAT Panaji16 Feb 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80P(2)(a)

Sangh Limited. 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

Choday Janaki Ramayya Chowdary, Visakhapatnam vs. Income Tax Officer, Ward-1, Kakinada

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

ITA 623/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam16 Feb 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble

Section 147Section 148Section 148ASection 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

Mandeep Kaur, Fatehabad vs. ITO, Ward - 1, Fatehabad

The appeal stand allowed

ITA 630/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh16 Feb 2026AY 2016-17

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.630/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2016-17) Ms. Mandeep Kaur Ito Ward -1 बनाम/ Vs. Vpo Museh Ali Hizrawan, Khurd, To Fatehabad Rohtak - 124001 Fatehabad, Haryana – 125050 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Datpk-9813-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Mukesh Kumar Jain (Ca) – Ld. Ar (Virtual) ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.02.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016- 17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 17-02-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 147 R.W.S. 144Of The Act On30-04-2023. 2. The Ld. Ar, At The Outset, Urged Legal Ground No.4 To Assail The Jurisdiction Of Ld. Ao. In This Ground Of Appeal, It Has Been Pleaded That The Order Passed U/S 148A(D) As Well As Issue Of Notice U/S 148

For Appellant: Sh. Mukesh Kumar Jain (CA) – Ld. AR (Virtual)For Respondent: Sh. Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 147Section 148Section 148ASection 151

from Joint Commissioner of the old the end of the relevant regime assessment year Section 151(1) After expiry of four years from Principal Chief Commissioner or Chief of the old the end of the relevant Commissioner or Principal regime assessment year Commissioner or Commissioner Section 151(i) Three years ... years from the end of the Director or Commissioner or Director regime relevant assessment year Section 151(ii) More than three years have Principal Chief Commissioner or of the new elapsed from the end of the Principal Director General or Chief regime relevant assessment year Commissioner or Director General

Adarsh Developers, Mumbai vs. ITO, Ward 22(3)(1), Mumbai

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

ITA 7945/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 147Section 148Section 148ASection 151Section 151ASection 50CSection 50C(2)

approve the issuance of notice u/s 148 of the new regime, as per section 151 of the Act, would be the Principal Chief Commissioner of Income Tax or the Chief Commissioner of Income Tax. The Ld. AR placed reliance on the decision of the Hon’ble Supreme Court ... Joint Commissioner; and 8 I.T.A. No. 7945/Mum/2025 (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. 75. After 1 April 2021, the new regime has specified different authorities for granting sanctions under section

Vicky Navani, Jabalpur vs. Income Tax Officer, Ward 1(3), Jabalpur, Ward ))

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

ITA 124/JAB/2024[2016-17]Status: DisposedITAT Jabalpur13 Feb 2026AY 2016-17

Bench: Shri Anadee Nath Misshra

Section 253(3)Section 271Section 271BSection 273BSection 275Section 44A

Joint Commissioner (Appeals) or the Commissioner (Appeals) or, as the case may be, the Appellate Tribunal is received by the 75[Principal Chief Commissioner or] Chief Commissioner or 75 [Principal Commissioner or] Commissioner, whichever period expires I.T.A. No.124/JAB/2024 Assessment Year:2016-17 8 76 [Provided that in a case where ... financial year in which the order of 768 [the Joint Commissioner (Appeals) or] the Commissioner (Appeals) is received by the 77 [Principal Chief Commissioner or] Chief Commissioner or 77 [Principal Commissioner or] Commissioner, whichever is later.] (b) in a case where the relevant assessment or other order is the subject

Shree Mahila Credit Souhard Sahakari Sangh Niyamit, Belagavi vs. ITO Ward 1 Belagavi, Belagavi

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

ITA 116/PAN/2024[2017-18]Status: DisposedITAT Panaji13 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.116/Pan/2024 (A.Y. 2017-18) Shree Mahila Credit Souhard Vs Ito-Ward-2, Sahakari Sangh Niyamit, Feroj Khimjibhai Cpx, . Shop.No.3, Maruti Complex, Civil Hospital Road 2 Nd Railway Gate, Tilakwadi, Belagavi-590001. Belgaum-500006, Karnataka. Karnataka. . Pan .No. Aabas9244A (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Pramod Y Vaidya.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.02.2026 घोषणा की तारीख/Date Of Pronouncement 13.02.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of The Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Partially Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Act Made By The Assessing Officer & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act & Sustaining Denial Of Deduction Of Interest On Income Tax Refund Under Section 80P(2)(A)(I) Of The Act.

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

Shree Maru Kansara Soni Gnati, Anjar vs. ITO Exemption Ward-1 Rajkot, Rajkot

In the result, appeal filed by the assessee is allowed

ITA 789/RJT/2025[2017-18]Status: DisposedITAT Rajkot13 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 789/Rjt/2025 धििाारण वर्ा/Assessment Year: (2017-18) Shree Maru Kansara Soni Gnati बनाम Income Tax Officer (Exemption), /Vs. C/O Rajesh K Soni, Shashtri Road, Ward- 1, Rajkot, Anjar, Kutch-360 001(Gujarat) It Office, New Aayakar Bhavan,Vatiaka, Rajkot-360 001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aarts 1920 N (Appellant) (Respondent)

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Gopi Nath Chaubey, Ld. Sr. DR
Section 115BSection 142(1)Section 143(1)Section 143(2)Section 144Section 147Section 148Section 234ASection 250Section 274

which triggers reassessment under Section 147), the Assessing Officer must obtain prior approval from the specified higher authority (e.g., Commissioner, Principal Commissioner, Principal Chief Commissioner, etc., as applicable) and must record the reasons on which this approval is based. The statutory scheme makes this a condition precedent to the validity

Venkata Rao Pogarthi, Narsaraopet vs. Neac (CIT Appeals), Delhi

In the result, appeal of the assessee is allowed

ITA 426/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam13 Feb 2026AY 2018-19

Bench: Itat With A Delay Of 55 Days. During The Hearing Proceedings Before

Section 147Section 148Section 151Section 254(1)Section 69

more than 3 years have elapsed from the end of relevant assessment year, then, the specified authority to sanction approval would be Principal Chief Commissioner of Income Tax, whereas in the impugned case, the sanction was accorded by the PCIT only. Reliance was placed on the batch petitions ... prescribed authority only. In other words, where a period of 3 years elapsed, approval to reopen the assessment should be taken from Principal Chief Commissioner of 7 Venkat Rao Pogarthi Income Tax, whereas, in the impugned case, approval was obtained from Principal Commissioner of Income Tax. 11. In view

M/S. Bodal Chemicals Limited, Ahmedabad vs. The Dy.CIT., Central Circle-1(1), Ahmedabad

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

ITA 104/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Alpesh Parmar, CIT (DR)
Section 250Section 35(1)(ii)Section 80Section 801ASection 80A(5)Section 80I

Ministry of Finance Department of Revenue Central Board of Direct Taxes ******************** Room No. 245A, North Block, New Delhi 14th December, 2018 To All Principal Chief Commissioners of Income Tax All Director Generals of Income Tax (Investigation) Sir/Madam Subject: Information regarding bogus donation racket under section 35(1)(ii) of Income

DCIT Central Circle- 7(1), Mumbai vs. Bhavik Prafulchandra Vora, Gujrat

In the result, the appeal filed by the revenue is dismissed and cross-objection filed by assessee is partly allowed

ITA 7602/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 151Section 151ASection 68

beyond period of three years, approval was required to be taken as per the provisions of section 151 of the Act i.e. from Pr. Chief Commissioner or Pr. Director General or Chief Commissioner or Director General of Income Tax and not from Pr. Commissioner of Income Tax. 2. The reopening ... regime, as per section 151 of the Act, would be the Principal 5 I.T.A. No. 7602/Mum/2025 C.O. No. 20/Mum/2026 Chief Commissioner of Income Tax or the Chief Commissioner of Income Tax. The Ld. AR placed reliance on the decision of the Hon’ble Supreme Court in the case of Union

DCIT Central Circle- 7(1), Mumbai vs. Pranavkumar Prafulchandra Vora, Gujrat

In the result, the appeal filed by the revenue is dismissed and cross-objection filed by assessee is partly allowed

ITA 7596/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 147Section 148Section 151ASection 68

which was issued with the approval of PCIT, whereas the appropriate 3 I.T.A. No. 7596/Mum/2025 C.O. No. 22/Mum/2026 authority for granting approval was Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. 2. In law and in the facts and circumstances of the casc ... I.T.A. No. 7596/Mum/2025 C.O. No. 22/Mum/2026 new regime, as per section 151 of the Act, would be the Principal Chief Commissioner of Income Tax or the Chief Commissioner of Income Tax. The Ld. AR placed reliance on the decision of the Hon’ble Supreme Court in the case of Union

Surat Goods Transport Pvt Ltd, Mumbai vs. DCIT Circle 16(2), Mumbai

ITA 7556/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Feb 2026AY 2018-19

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

Section 143(3)Section 144Section 144BSection 147Section 148Section 148ASection 154Section 68

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 [*] Chief Commissioner or Director General, if more than three years have elapsed from the end of the relevant assessment year ... three years from the end of AY 2018-19 (ended on 31.03.2018), therefore the specified authority in present case would be the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General of Income Tax, whereas the approval was granted by Pr. CIT, who does not have

Dattatray Vithoba Sawant, Kalyan vs. Income Tax Officer, WD-42(2)(2), Mumbai

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

ITA 6081/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 10(14)Section 133ASection 142(1)Section 148Section 148ASection 151Section 151ASection 3Section 80CSection 80G

approve the issuance of notice u/s 148 of the new regime, as per section 151 of the Act, would be the Principal Chief Commissioner of Income Tax or the Chief Commissioner of Income Tax. The Ld. AR placed reliance on the decision of the Hon’ble Supreme Court ... after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. 75. After 1 April 2021, the new regime has specified different authorities for granting sanctions under

Rajendrakumar Shrishrimal, Pune vs. Income Tax Officer Ward 5(1), Pune

In the result, appeal of the assessee is allowed

ITA 3282/PUN/2025[2017-18]Status: DisposedITAT Pune12 Feb 2026AY 2017-18

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.3282/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Rajendrakumar Shrishrimal, V The Income Tax Officer, 685/3, Anant Vashat, S Ward-5(1), Pune. Bibwewadi, Pune – 411037. Pan: Bjsps9226G Appellant/ Assessee Respondent /Revenue Assessee By Shri Abhilash Hiran Revenue By Shri Sadananda – Jcit(Dr) Date Of Hearing 11/02/2026 Date Of Pronouncement 12/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 16.10.2025 Emanating From The Assessment Order Passed Under Section 147 Read With Section 144B Of The I.T.Act, 1961 Dated 03.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144BSection 147Section 148Section 151Section 250

while issuing the notice under section 148 of the Act dated 27 July 2022 instead of obtaining approval from the learned Principal Chief Commissioner of Income-tax under section 151 (ii) of the Act, hence the reassessment notice issued and consequential order passed may be quashed and set aside ... A.Y.2017-18. As per section 151(ii) of the Act, after lapse of three years from the end of assessment year approval of Principal Chief Commissioner of Income Tax(Pr.CCIT) or Chief Commissioner of Income Tax(CCIT) was required. 5. Ld.AR for the assessee relied on the following decisions

Prabhulal Kalji Doshi, Mumbai vs. ITO Ward 19(2)(4), Mumbai

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

ITA 7421/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 148ASection 151Section 68

reopening notice u/s 148 on 28/07/2022, approval was required to be taken as per provisions of amended section 151 of the Act from Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General, however approval is from PCIT. The approval is not in accordance with law, therefore ... approve the issuance of notice u/s 148 of the new regime, as per section 151 of the Act, would be the Principal Chief Commissioner of Income Tax or the Chief Commissioner of Income Tax. The Ld. AR placed reliance on the decision of the Hon’ble Supreme Court

Shekh Ikbal Husen, Dehradun vs. ITO Ward 1(1)(3), Dehradun

In the result, Appeals of the Assessee is allowed

ITA 221/DDN/2025[2013-14]Status: DisposedITAT Dehradun11 Feb 2026AY 2013-14

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthisheikh Ikbal Husen Vs Assessment Unit 89, Kohinoor Niwas, Sewlakalan, Income Tax Officer, Ward Majra, Dehradunh, 248001, 1(1) (3) Aaykarbhawan, Uttarakhand 13-A, Subhash Road, Pan: Abkph0787Q Dehradun Appellant Respondent Assessee By Sh. Pankajgoel, Adv Revenue By Sh. A. S. Rana, Sr. Dr Date Of Hearing 09/02/2026 Date Of Pronouncement 11/02/2026

Section 148Section 151

cases of information received from any income tax authority requiring action under Section 148 of the Act with the approval of Chief Commissioner of 3 Sheikh Ikbal Husen Income Tax concerned can be issued. Further clarification was made on 12th March, 2021 wherein it was clarified vide instruction F.No.225/40/2021/ITA-II

Mukunda Pandit Chaugule, Pandhurli vs. Income Tax Officer, Nashik

In the result, appeal of the assessee is allowed

ITA 3194/PUN/2025[2017-18]Status: DisposedITAT Pune11 Feb 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3194/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Mukunda Pandit Chaugule, V The Income Tax Officer, 471A, Shimpi Lane, Pandurli S Nashik. B.O., Pandhurli, Nashik – 422502 Pan: Atepc5427G Appellant/ Assessee Respondent /Revenue Assessee By Shri Sanket Joshi (Virtual) Revenue By Shri Sadananda – Jcit(Dr) Date Of Hearing 10/02/2026 Date Of Pronouncement 11/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 26.09.2025 Emanating From The Assessment Order Passed Under Section 147R.W.S 144 Read With Section 144B Of The I.T.Act, 1961 Dated 20.04.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144BSection 147Section 147rSection 148Section 151Section 151ASection 153CSection 250Section 69A

A.Y.2017-18. As per section 151(ii) of the Act, after lapse of three years from the end of assessment year approval of Principal Chief Commissioner of Income Tax(Pr.CCIT) or Chief Commissioner of Income Tax(CCIT) was required. ITA No.3194/PUN/2025 [A] 6. The Hon’ble Delhi High Court ... apparent from the said notice that it was not issued with the prior approval of the Principal Chief Commissioner of Income Tax (PCCIT) or any other authority specified under Section 151(ii) of the Act. Such approval is mandatory for issuance of a notice issued under Section

Kesireddy Ravinder Reddy, Hyderabad vs. ITO Ward-11(1), Hyderabad

ITA 1617/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.1617 & 1722/Hyd/2025

For Appellant: Sri Mohd Afzal, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(1)Section 269SSection 271DSection 274Section 275

order of 4 the Deputy Commissioner (Appeals) or] the Commissioner (Appeals) or, as the 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