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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

ACIT, Circlle-34, Kolkata vs. Subhas Kumar Kedia, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1677/KOL/2024[2016-17]Status: DisposedITAT Kolkata17 Apr 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri P.N.Barnwal, CIT-DR
Section 148Section 148ASection 149Section 151Section 246ASection 3Section 69A

Assessing Officer, after the expiry of a period of four years from the end of the relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer, that it is a fit case ... case for the issue of such notice. (3) For the purposes of sub-section (1) and sub-section (2), the Principal Chief Commissioner or the Chief Commissioner or the Principal Commissioner or the Commissioner or the Joint Commissioner, as the case may be, being satisfied on the reasons recorded

Stc Securities Private Limited, Mumbai vs. Assessment Unit Income Tax Department, Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 82/MUM/2025[2016-17]Status: DisposedITAT Mumbai16 Apr 2025AY 2016-17

Bench: Shri Sandeep Gosain & Smt. Renu Jauhri

Section 148Section 148ASection 149(1)Section 149(1)(b)Section 250

Director, if three years or less than three years have elapsed from the end of the relevant assessment year; Manish Financial (11) 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

Stc Securities Private Limited, Mumbai vs. Assessment Unit Incoem Tax Department, Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 81/MUM/2025[2015-16]Status: DisposedITAT Mumbai16 Apr 2025AY 2015-16

Bench: Shri Sandeep Gosain & Smt. Renu Jauhri

Section 148Section 148ASection 149(1)Section 149(1)(b)Section 250

Director, if three years or less than three years have elapsed from the end of the relevant assessment year; Manish Financial (11) 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

Harikrishna Jewels, Surat vs. Pr. Commissioner of Income Tax, Surat

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

ITA 354/SRT/2023[2012-13]Status: DisposedITAT Surat15 Apr 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.354/Srt/2023 Assessment Year: 2012-13 (Physical Court Hearing) Harikrishna Jewels, Principal Commissioner Of 201, Sunstar Building, Opp. बनाम/ Income Tax-1,, Surat, Room New Patidar Bhavan, No.123, Aaykar Bhawan, Near Vs. Mahidharpura, Surat-395 Majura Gate, Opp. New Civil 003 Hospital, Surat -395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagfh 3864 F (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri Rasesh Shah, Ca राज" की ओर से /Revenue By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 10.02.2025 उद्घोषणा की तारीख/Date Of Pronouncement 15.04.2025

Section 10ASection 143(3)Section 148Section 263

pass such order as the circumstances of the case justify. For ready reference, section 263 of the Act reproduced below: “263. (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 fa 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 ha been made

Lalit Surajprakash Garg, Mumbai vs. DCIT, Central Circle-6(2), Mumbai

In the result, the appeals in ITA 6125/Mum/2024 (A

ITA 6126/MUM/2024[2017-18]Status: DisposedITAT Mumbai15 Apr 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Gaurav Bansal,CAFor Respondent: Shri Ram Krishn Kedia (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 149(1)

Lalit Surajprakash Garg 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General. As against this specific requirement of section 151(ii), it is clear that u/s 148A(d) as well as for the notice ... assessment year, the appropriate authority for the purpose of section 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General.As against this specific requirement of section 151(ii), it is clear from the order u/s. 148A

Lalit Surajprakash Garg, Mumbai vs. DCIT, Central Circle-6(2), Mumbai

In the result, the appeals in ITA 6125/Mum/2024 (A

ITA 6125/MUM/2024[2016-17]Status: DisposedITAT Mumbai15 Apr 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Gaurav Bansal,CAFor Respondent: Shri Ram Krishn Kedia (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 149(1)

Lalit Surajprakash Garg 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General. As against this specific requirement of section 151(ii), it is clear that u/s 148A(d) as well as for the notice ... assessment year, the appropriate authority for the purpose of section 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General.As against this specific requirement of section 151(ii), it is clear from the order u/s. 148A

Lalit Surajprakash Garg, Mumbai vs. DCIT, Central Circle-6(2), Mumbai

In the result, the appeals in ITA 6125/Mum/2024 (A

ITA 6124/MUM/2024[2015-16]Status: DisposedITAT Mumbai15 Apr 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Gaurav Bansal,CAFor Respondent: Shri Ram Krishn Kedia (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 149(1)

Lalit Surajprakash Garg 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General. As against this specific requirement of section 151(ii), it is clear that u/s 148A(d) as well as for the notice ... assessment year, the appropriate authority for the purpose of section 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General.As against this specific requirement of section 151(ii), it is clear from the order u/s. 148A

Lalit Surajprakash Garg, Mumbai vs. DCIT, Central Circle-6(2), Mumbai

In the result, the appeals in ITA 6125/Mum/2024 (A

ITA 6123/MUM/2024[2014-15]Status: DisposedITAT Mumbai15 Apr 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Gaurav Bansal,CAFor Respondent: Shri Ram Krishn Kedia (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 149(1)

Lalit Surajprakash Garg 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General. As against this specific requirement of section 151(ii), it is clear that u/s 148A(d) as well as for the notice ... assessment year, the appropriate authority for the purpose of section 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General.As against this specific requirement of section 151(ii), it is clear from the order u/s. 148A

Lalit Surajprakash Garg, Mumbai vs. DCIT, Central Circle-6(2), Mumbai

In the result, the appeals in ITA 6125/Mum/2024 (A

ITA 6122/MUM/2024[2013-14]Status: DisposedITAT Mumbai15 Apr 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Gaurav Bansal,CAFor Respondent: Shri Ram Krishn Kedia (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 149(1)

Lalit Surajprakash Garg 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General. As against this specific requirement of section 151(ii), it is clear that u/s 148A(d) as well as for the notice ... assessment year, the appropriate authority for the purpose of section 148 and section 148A of the Act is the Principle Chief Commissioner or Principle Director General or Chief Commissioner or Director General.As against this specific requirement of section 151(ii), it is clear from the order u/s. 148A

Kishan Beej, Jamnagar vs. ITO Ward 2(1), Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 384/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Apr 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.384/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Kishan Beej Ito, Wared-2(1) बनाम Kashivishvanath Road Jamnagar – 361 001 Nr. P & T Office Vs. Jamnagar – 361 001 Pan : Aacfk 2114 P (अपीलाथ"/Appellant) (""यथ"/Respondent) :

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 115BSection 142(1)Section 147Section 148Section 234ASection 250Section 271ASection 69Section 69A

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

ITO, Ward-2, Rohtak vs. Jai Singh, Rohtak

In the result, the appeal of the Revenue is allowed for statistical purpose

ITA 8284/DEL/2018[2010-11]Status: DisposedITAT Delhi11 Apr 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2010-11]

Section 144Section 147Section 148Section 274

Income Tax Officer, Ward-2, Rohtak. 2. Brief facts of the case:- In this case information was received from office of the Pr. Chief Commissioner of Income Tax, North West Region, Aaykar Bhawan, Sector-17E, Chandigarh in respect of total cash deposit amounting to Rs.1

Transunion International Inc., Mumbai vs. Deputy Comm. of Income Tax (International Taxation)-4(1)(2), Mumbai

Appeal of the assessee is allowed

ITA 2698/MUM/2022[2017-18]Status: DisposedITAT Mumbai11 Apr 2025AY 2017-18

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri J.D. Mistry, Sr. Adv. a/w
Section 142(1)Section 143(3)Section 144CSection 47

excess of the legitimate tax due from Petitioner. Mr. Mistri took us through the documents on record including the affidavits filed by the Chief Commissioner of Income-tax (International Taxation and Transfer Pricing) West Zone, Mumbai and also that filed by the Joint Commissioner of Income Tax, Ratlam ... ANITA VIJAYNATH KUNDER) ITO HQ TO DRP 2 WZ MUMBAI - 400005 022-22180539 4. Therefore, it will be more appropriate if the Chief Commissioner or Principal Chief Commissioner or whoever is the person heading the Dispute Resolution Panel files an affidavit explaining, inter alia, as to why when the Faceless

Mark Foods, Mumbai vs. Income Tax Officer-28(2)(1), Mumbai

In the result, both the appeals filed by assessee are allowed

ITA 4102/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 Apr 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Girish Agrawal

For Appellant: Shri Shashank Mehta, CAFor Respondent: Shri R. R. Makwana, Addl. CIT
Section 143Section 147Section 148Section 151ASection 153CSection 68

amended provisions by obtaining an invalid sanction u/s 151(i) from Pr. CIT-27, Mumbai which was ought to have been obtained from Principal chief commissioner of income tax as per section 151(ii) since a period of 3 years has elapsed from the end of the relevant assessment year ... Commissioner or Director, if three years or less than three years have lapsed from the end of the Assessment Year. ii. By Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General, if more than three years have been lapsed from the end of the relevant Assessment

Brightech Valves & Controls Pvt. Ltd., Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 52/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad08 Apr 2025AY 2012-13

Bench: Dr. Brr Kumar & Ms Suchitra Kamblei.Ta. No.52/Ahd/2025 (Assessment Year: 2012-13) Brightech Valves & Controls Vs. Deputy Pvt. Ltd., Commissioner Of Plot No.345, Gidc Kathwada. Income Tax, Kathwada, Circle-1(1)(1), Ahmedabad-382430. Ahmedabad.

For Appellant: Adjournment Application FiledFor Respondent: Shri Sudhakar Verma, Sr.DR
Section 131Section 143(3)Section 147Section 148Section 250(6)Section 35(1)(ii)

Revenue Asst.Year –2012-13 - 9– Central Board of Direct Taxes Room N0. 245A, North Block New Delhi, the 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

Income Tax Officer 23 3 6, Piramal Chambers vs. Rahul Hariprasad Tibrewal, Mumbai

ITA 430/MUM/2025[2017-18]Status: DisposedITAT Mumbai08 Apr 2025AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: Shri Dharmesh ShahFor Respondent: Shri R. R. Makwana
Section 144BSection 147Section 148Section 148ASection 250

circumstances of the present case the first 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 ITA No. 430/Mum/2025 & C.O. No. 63/Mum/2025 Assessment Year 2017-2018 for passing order under Section ... 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

Uniquestar Gems (India) Pvt. Ltd., Mumbai vs. The ITO, Ward 13(2)(1), Mumbai.

In the result the appeal filed by the assessee for A

ITA 1036/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Apr 2025AY 2013-14

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 148Section 148ASection 68

days time to the assessee to file its response. Subsequently, order u/s. 148A(d) was passed on 28/07/2022. After taking approval from the chief Commissioner of Income Tax Central 1 Mumbai notice u/s.148 was issued on 29/07/2022. 4.4 The Ld.AR submitted that, the notice issued u/s.148 of the new regime

Uniquestar Gems (India) Pvt. Ltd., Mumbai vs. The ITO, Ward 13(2)(1), Mumbai.

In the result the appeal filed by the assessee for A

ITA 1035/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Apr 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 148Section 148ASection 68

days time to the assessee to file its response. Subsequently, order u/s. 148A(d) was passed on 28/07/2022. After taking approval from the chief Commissioner of Income Tax Central 1 Mumbai notice u/s.148 was issued on 29/07/2022. 4.4 The Ld.AR submitted that, the notice issued u/s.148 of the new regime

Sudhir Singh Yadav, Gurgaon vs. DCIT, Circle 3(1), Gurgaon

ITA 3001/DEL/2023[2013-14]Status: DisposedITAT Delhi07 Apr 2025AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Debesh Panda, Special counsel for the Department
Section 132(4)Section 153ASection 50Section 68

reported in 2008 (4) TMI 4 - Supreme Court, in para 6 observed as under:- ―Similarly, the requirement of previous approval of the Chief Commissioner or the Commissioner in terms of the said provision being an inbuilt protection against any arbitrary or unjust exercise of power by the Assessing Officer, casts ... requirement of the previous approval, envisaged in the Section is not turned into an empty ritual. Needless to emphasise that before granting approval, the Chief Commissioner or the Commissioner, as the case may be, must have before him the material on ITA Nos. 2999 to 3005/Del/2024 Sushen Mohan Gupta

Joseph Mathew Kunnathettu, Mumbai vs. The Assistant Commissioner of Income Tax, Circle-3, Kalyan

In the result, the appeal is accordingly allowed in the above terms

ITA 899/MUM/2024[2012-13]Status: DisposedITAT Mumbai04 Apr 2025AY 2012-13

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanjoseph Mathew Kunnathettu Vs. Acit Circle 3, 14, Trimurthi Apartment, Gandhi 2Nd Floor, Rani Mansion, Nagar, Dombivili (E), Maharashtra – Murbad Road Kalyan, 421 201 Maharashtra – 421 301 Pan: Ailpk9660M (Appellant) (Respondent)

Section 142(1)Section 148Section 2(22)(e)Section 250Section 271(1)(c)Section 68Section 69A

such notice.] Joseph Mathew Kunnathettu [Explanation.- For the removal of doubts, it is hereby declared that the Joint Commissioner, the Commissioner or the Chief Commissioner, as the case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice

Nikesh Govindrao Rathod, Mumbai vs. ITO Ward 41(2)(3), Mumbai

In the result the appeal filed by the assessee is partly allowed with no orders as to cost

ITA 3947/MUM/2024[2016-17]Status: DisposedITAT Mumbai04 Apr 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Smt. Renu Jauhrinikesh Govindrao Rathod Vs. Ito, Ward – 41(2)(3) D-801, Teakwood, Room No. 732, Kautilya Swapnanagri, Vasant Bhavan, Bkc, Bandra Garden, Mulund (W), (E). Mumbai – 400080. Pan/Gir No. Atrpr6189D (Applicant) (Respondent)

Section 148Section 148ASection 151Section 151ASection 250Section 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 where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three ... have been obtained under the amended provisions of section 151(ii) of the Act i.e. the approval should have been obtained from the Principal Chief Commissioner whereas the approval has been obtained from Pr.CIT as stated in the notice under section 148 itself. Therefore we see merit in the contention