“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

Nikhil Banga Kalyan Samity, Kolkata vs. ITO, Ward 1(1), Exempt, Kolkata

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

ITA 2807/KOL/2025[2021-2022]Status: DisposedITAT Kolkata11 Feb 2026AY 2021-2022

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 11Section 11(2)Section 12ASection 139(1)Section 143(1)Section 143(1)(a)Section 154Section 250

Circular No. 16 of 2022 dated 19-07-2022 issued under Section 119(2)(b) by which the powers delegated to the Principal Chief Commissioner of Income Tax/Commissioner of Income Tax to condone the delay in filing Form 10B beyond 365 days up to 3 years from the assessment year

Rmkv Fashion Garments Private Limtied, Tirunelveli vs. DCIT Cricle-1, Tirunelevli, Tirunelveli

In the result, appeal filed by the assessee is allowed & Stay Petition

ITA 394/CHNY/2026[2016-17]Status: DisposedITAT Chennai11 Feb 2026AY 2016-17

Bench: Shri Aby T. Varkey & Ms. Padmavathy Sआयकर अपील सं./Ita No.394/Chny/2026 िनधा"रण वष"/Assessment Year: 2016-17 & Stay Petition No.31/Chny/2026 िनधा"रण वष"/Assessment Year: 2016-17 V. Rmkv Fashion Garment Pvt. Ltd, The Dcit Circle – 1, (Now Merged With Rmkv Fabrics Pvt. Tirunelveli. Ltd,) 176F Trivandrum Road, Vannarpettai, Tirunelveli – 627 003. [Pan: Aafcr 4023 G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. G. Baskar, Advocate & P.M. Kathir, Advocate ""यथ" क" ओर से /Respondent By : Mr. Bipin C.N, Cit

For Appellant: Mr. G. Baskar, Advocate &For Respondent: Mr. Bipin C.N, CIT

Section 148Section 148ASection 151

relevant assessment 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 ... 31/Chny/2026 RMKV Fashion Garment Pvt. Ltd, (Now merged with RMKV Fabrics Pvt.Ltd,) :: 5 :: 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 of sanction by the appropriate/specified authority u/s 151 is a pre-condition

Sulthankhan Amanulla, Dharmapuri vs. ITO Ward 1, Dharmapuri

In the result, all the three appeals filed by the assessee are allowed

ITA 3455/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.T.S. LakshmiFor Respondent: Mrs. Anitha, Addl.CIT

Section 148Section 148ASection 151Section 270ASection 271B

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 ... Sulthankhan Amanulla :: 4 :: 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 of sanction

DCIT Circle-28(1), Civic Centre New Delhi vs. Ashwani Khurana, New Delhi

ITA 4534/DEL/2024[2016-17]Status: DisposedITAT Delhi11 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwaldcit, Circle 28(1) Vs. Ashwani Khurana Room No. 1001, 10Th Floor 5, Green Avenue Vasant E-2, Block Civic Centre, Kunj, New Delhi – 110002 New Delhi – 110070 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaepk3731G Appellant .. Respondent

For Appellant: Sh. A.K. Khurana, CAFor Respondent: Sh. Jitender Singh, CIT, DR

Section 147Section 148Section 148ASection 151Section 151A

dated 30/07/2022 i.e after the lapse of three years from the end of the relevant assessment year. The specified authority would thus be Principal Chief Commissioner of Income Tax. In this regard, reliance as placed by the Ld. AR on the decision of Coordinate bench in the case of Sampark ... section 151 of the Act, if more than three years have lapsed from the end of the relevant assessment year, approval of Principal Chief Commissioner of Income-tax or Principal Director General or Chief Commissioner or Director General was required to be obtained. In the present assessment years, notices

S.D Education Society, Karnal vs. DCIT Exemption, Chandigarh

In the result, both the appeals are allowed for statistical purposes

ITA 1088/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh10 Feb 2026AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 1087 & 1088/Chd/2025 "नधा"रण वष" / Assessment Year: 2017-18 & 2018-19 S.D. Education Society, The Dcit (Exemptions), S.D. Model Sr. Section. School, Vs Chandigarh. Railway Road, Karnal. "थायी लेखा सं./Pan No: Aabas5001P अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Girish Aneja, Ca Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr. Dr Date Of Hearing : 09.02.2026 Date Of Pronouncement : 10.02.2026

For Appellant: Shri Girish Aneja, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr. DR

Section 249Section 253Section 3Section 5

denied to the assessee by the AO because assessee has claimed the exemption on the basis of registration granted u/s 10(23C)(vi) by Chief Commissioner of Income Tax, Panchkula. However, according to the AO, the assessee failed to submit approval granted by the Chief Commissioner under above provision ... counsel for the assessee submitted that assessee has filed a Writ Petition bearing No. 10104 of 2011 vide which action of the Chief Commissioner of Income Tax rejecting approval ITA No.1087 & 1088/CHD/2025 A.Y.2017-18 & 2018-19 7 admissible to the assessee u/s 10(23C) was challenged. The Hon'ble High Court

S.D Education Society, Karnal vs. DCIT Exemption, Chandigarh

In the result, both the appeals are allowed for statistical purposes

ITA 1087/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh10 Feb 2026AY 2017-18

For Appellant: Shri Girish Aneja, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr. DR

Section 249Section 253Section 3Section 5

Palanisamy Shankarganesh, Erode vs. ITO Ward 1, (1), Erode

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

ITA 3544/CHNY/2025[2018-19]Status: DisposedITAT Chennai10 Feb 2026AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./Ita No.: 3544/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Shri Palanisamy Shankarganesh The Income Tax Officer, Prop: Universal Communication, Vs. Ward-1(1), No.56, Mettur Road, Erode, Erode. Tamil Nadu-638 001. [Pan: Azsps4331D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr.Bhupendran, Advocate ""यथ" क" ओर से/Respondent By : Mr.Sbr Kumar Laghimsetti, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 20.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 10.02.2026

For Appellant: Mr.Bhupendran, AdvocateFor Respondent: Mr.SBR Kumar Laghimsetti

Section 142(1)Section 143(1)Section 147Section 148Section 148ASection 151

Principal Commissioner of Income Tax, Coimbatore-1 as evident from the order passed u/s.148A(d) and 148 of the Act, instead of Principal Chief Commissioner of Income Tax or the Chief Commissioner of Income Tax, since the period of more than three years had elapsed from ... period of three years elapsed from the relevant assessment year, AO has to obtain approval from the specified authority who is the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. The relevant provisions as they stood at the relevant point of time are as under

Devanshi Sharma, Mumbai vs. ITO Ward 34(1)(1), Mumbai

In the result, the appeal is allowed as indicated above

ITA 7007/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardevanshi Sharma Ito, Ward 34(1)(1) 216, 2Nd Floor, Kautaliya Bhawan, Sagar Jyoti, Plot No. 18, Vs. 6Th Road, Jvpd Scheme, G-Block, Bandra Kurla Complex, Vile Parle (W), Mumbai-400 056 Bandra (E), Mumbai-400 051 Pan/Gir No. Cmvpk 6007 Q (Appellant) : (Respondent) Appellant By : Shri Shashank Mehta Respondent By : Shri Annavaram Kosuri Date Of Hearing : 05.02.2026 Date Of Pronouncement : 10.02.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against Order Dated 27.10.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2017-18. 2. In Ground No. 1, The Assessee Has Raised A Pertinent Legal Issue, Challenging The Validity Of The Order Passed U/S. 148A(D) Of The Income Tax Act, 1961 (‘The Act’ For Short) As Also The Notice Issued U/S. 148 Of The Act. Since, The Aforesaid Issue Raised By The Assessee Is A Purely Legal & Jurisdictional Issue Going To The Root Of The Matter & Affecting The Validity Of The Proceedings Initiated U/S. 147 Of The Act, We Are Inclined To Address The Issue At The Very Outset.

For Appellant: Shri Shashank MehtaFor Respondent: Shri Annavaram Kosuri

Section 10(38)Section 147Section 148Section 148ASection 151

notice u/s. 148 of the Act, after expiry of more than three years from the end of the relevant assessment year is the Principal Chief Commissioner of Income Tax (PCCIT for short). Whereas, he submitted, the A.O. has passed the order u/s. 148A(d) of the Act and issued notice ... taken u/s. 148A(d) and 148 of the Act, after obtaining approval/sanction of PCCIT or Principal Director General of Income Tax or Chief Commissioner of Income Tax or Chief Director General of Income Tax. In the facts of the instant case, approval/sanction for taking action u/s. 148A

Deputy Commissioner of Income Tax Central Circle - 5(3), Mumbai vs. Unify Texturisers Private Limited, Mumbai

ITA 5055/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawaldcit Central Circle-5(3), Vs Unify Texturisers Private Limited Mumbai 3Rd Floor, Astral Centre, Nm Joshi Kautilya Bhawan, Bandra Marg, Opp. Chinchpokli Railway Kurla Complex, Bandra (East) Station, Mumbai-400011 Mumbai 400051 Pan: Aaacu8565F Appellant Respondent C.O. No.241/Mum/2025 (Arising Out Of I.T.A. No.5055/Mum/2025 A.Y. :2017-18)

For Appellant: Shri Jay BhansaliFor Respondent: Ms. Kavita Kaushik (SR DR)

Section 139(1)Section 147Section 148Section 148ASection 151Section 151(1)Section 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 ... after expiry of three years could be granted only by the authority specified under section 151(ii) of the 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

Nagpal, Uttar Pradesh vs. ITO Ward -2 (5), Chandausi

ITA 179/DEL/2026[2018-19]Status: DisposedITAT Delhi10 Feb 2026AY 2018-19

Bench: Sh. Satbeer Singh Godara

For Appellant: Sh. V. Rajkumar, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 147Section 148Section 148ASection 149(1)Section 151

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

Krishna, Delhi vs. ITO Ward 36(1), Delhi

Appeal is allowed in above terms

ITA 166/DEL/2026[2017-18]Status: DisposedITAT Delhi10 Feb 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 166/Del/2026 : Asstt. Year: 2017-18 Mrs. Krishna, Vs Income Tax Officer, G-2/57, Sector-11, Rohini, Ward-36(1), New Delhi-110085 New Delhi-110001 (Appellant) (Respondent) Pan No. Aijpd1120H Assessee By: Sh. Manish Kumar, Ca & Sh. Gaurav Bhujel, Ar Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082534866(1) Dated 12.11.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Manish Kumar, CA &For Respondent: Sh. Manoj Kumar, Sr. DR

Section 147Section 148Section 148ASection 149(1)Section 151

assessment year, thus, in terms of Section 151(ii) of the Act, the same was 3 Krishna 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 ... 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

Sahil Garg, Delhi vs. ITO Ward-43(6), Delhi

Appeal is allowed

ITA 76/DEL/2026[2017-2018]Status: DisposedITAT Delhi09 Feb 2026AY 2017-2018

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Sh. Sahil Garg, Income Tax Officer, G-930, Dsiidc Industrial Ward-43(3), Area, Narela, Delhi New Delhi Pan: Awxpg9338G (Appellant) (Respondent) Assessee By Sh. Sandeep Goel, Adv. Department By Sh. Manoj Kumar, Sr. Dr

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

Authority had obtained the necessary approval from the PCIT-15, 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

Rr Marketing, Hyderabad vs. ITO., Ward-9(1), Hyderabad

ITA 1218/HYD/2025[2015-16]Status: DisposedITAT Hyderabad06 Feb 2026AY 2015-16

For Appellant: Shri AV Raghuram, AdvocateFor Respondent: Shri K. Vamsi Krishna

Section 133(6)Section 147Section 148Section 148ASection 282

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC’ Bench, Hyderabad Before Shri Manjunatha G., Accountant

Rahul Meka, Bengaluru vs. Income Tax Officer, Ward International Taxation-1(2), Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 813/BANG/2024[2016-17]Status: DisposedITAT Bangalore06 Feb 2026AY 2016-17

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Dr. Divya K.J – CIT(DR)(ITAT), Bangalore

Section 147Section 45Section 54Section 54FSection 68

period of 3 years. Further it is submitted that as the approval is beyond three years ought to have been obtained from the Principal Chief Commissioner of Income Tax/ Principal Director General of Income Tax/ Chief Commissioner of Income Tax/ Director General of Income Tax as per provisions of section ... 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

Suman Jagannath Sankhe, Mumbai vs. ITO Ward 41.4.4, Kautilya Bhavan, Mumbai

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

ITA 7528/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai ()

Section 144BSection 148Section 148ASection 151Section 151ASection 68

present case since, as admitted by the Ld. AO himself, the sanction is obtained from the Principal Commissioner of Income Tax instead of the Chief Commissioner / Principal Chief Commissioner of Income Tax and therefore the entire proceeding is invalid and void ab initio; e. The impugned Notice under section ... escaping assessment is observed to be Rs.15,00,000/-. He submitted that the approval for issuance of such notice has been obtained from the Chief Commissioner of 6 I.T.A. No. 7528/Mum/2025 Income Tax–5, Mumbai. The Ld. AR submitted that the appropriate authority who has to approve the issuance

Late Chanchal Hiralal Shah (Represented by Legal Heir Rohit Hiralal Shah), Mumbai vs. ITO, Ward-20(1)(1), Mumbai

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

ITA 6349/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 148Section 148ASection 149Section 151Section 151ASection 56(2)(vii)

regime, issued beyond three years. Thus, it required sanction from the authority specified u/s 151(1) of the Act, namely the Principal Chief Commissioner or Chief Commissioner or Principal Director General or Director General, as the case may be. However, in the present case, approval was granted by the Principal ... years of the old from the end of the relevant Joint Commissioner regime assessment year Section 151(1) After expiry of four years Principal Chief Commissioner or of the old from the end of the relevant Chief Commissioner or Principal regime assessment year Commissioner or Commissioner Three years or less

Kuldip Kumar Goel, Delhi vs. ACIT(1)(1), Delhi

In the result, the appeal of the assessee is partly allowed in above

ITA 3285/DEL/2025[2012-13]Status: DisposedITAT Delhi06 Feb 2026AY 2012-13

Bench: Shri Raj Kumar Chauhanand

Section 143(3)Section 144Section 147Section 148Section 149(1)Section 250

Assessing Officer has jurisdiction to assess any person, the question shall be determined by the °[Principal Director General or] Director General or the ©[Principal Chief Commissioner or] Chief Commissioner or the 62[Principal Commissioner or] Commissioner; or where the question is one relating to areas within the jurisdiction of different ... Principal Directors General or] Directors General or © {Principal Chief Commissioners or] Chief Commissioners or ©¢ [Principal Commissioners or] Commissioners, by the 6¢[Principal Directors General or] Directors General or 6¢[Principal Chief Commissioners or] Chief Commissioners or 62a [Principal Commissioners or] Commissioners concerned or, if they are not in agreement

ITO, Mumbai vs. Himanshu Sarda, Mumbai

ITA 5862/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Feb 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarito,Ward-42(1)(2), Mumbai Vs Himanshu Sarda Room No. 734, Kautilya 705/706, Shivalaya Residency Chs Bhawan, Bkc, Bandra (E) Ltd., Thakur Complex, 90 Feet Mumbai-400051 Road, Kandivali East, Mumbai- 400101 Pan: Flpps9753F Appellant Respondent C.O.410/Mum/2025 (Arising Out Of I.T.A. No.5862/Mum/2025 A.Y. :2017-18)

For Appellant: Shri Ajay R. Singh, Adv & Akshay Pawar, AdvFor Respondent: Shri Ritesh Misra (CIT DR)

Section 147Section 148Section 148ASection 151Section 250

Ambuja Cements Limited, Mumbai vs. PCIT, Mumbai-3, Mumbai

ITA 3474/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Sourabh Soparkar, AR (virtually appear)For Respondent: Shri Rajesh Kumar Yadav, (CIT-DR)

Section 143(3)Section 14ASection 263

Explanation 2 of the Act brought into the statute w.e.f. 01.06.2025, as below: Section-263. Revision of orders prejudicial to revenue. (1)The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this ... deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— (a)the order is passed without making inquiries or verification which should have been made

Sarju Gurunamal Goklani, Beed vs. PCIT Circle -1, Jalgaon

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

ITA 974/PUN/2025[2020-21]Status: DisposedITAT Pune04 Feb 2026AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.974/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-12 Sarju Gurunamal Goklani, Vs. Pcit, Nashik-1. Kalaguru Sai Shraddha Nagar, Amalner- 425401. Pan : Aaopg7057M Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Amit Bobde Date Of Hearing : 24.11.2025 Date Of Pronouncement : 04.02.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.02.2025 Passed U/S 263 Of The It Act By Ld. Pcit, Nashik-1 [‘Ld. Pcit’] For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. Ld. Cit Erred In Law & On Facts In Invoking Jurisdiction Under Section 263 & Setting Aside Assessment Order For Fresh Assessment On The Ground That Assessment Has Been Framed Without Proper Verification & Without Applying Relevant Provisions Of The Act.

For Appellant: Smt. Deepa KhareFor Respondent: Shri Amit Bobde

Section 143(3)Section 263Section 80Section 801BSection 80I

deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,- (a) the order is passed without making inquiries or verification which should have been made