ANUMITA INFRASTRUCTURE PRIVATE LIMITED,MUMBAI vs. PCIT-4, MUMBAI

reassessment order passed under section 147 read with section 144B is itself void-ab-initio for want of valid approval under section 151

ACIT, CIRCLE 24(1) MUMBAI, MUMBAI vs. NILKAMAL CRATES & CONTAINERS, MUMBAI

Bench: Hon’Ble Justice (Retd.) C.V. Bhadang & Shri Arun Khodpia, Am

151 of the new regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. 8.2 Under new regime, if income escaping assessment is more than Rupees 50 lakhs, a reassessment

SHANTILAL NAROTTAMDAS PANCHAL,MALAD EAST vs. ITO-41(3)(4), MUMBAI, BANDRA KURLA COMPLEX

Appeal is allowed

Bench: Him.

reassessment notice for assessment year 2017-2018 under Section 149(1)(a). This harmonious reading gives effect to the legislative intention of both the Income Tax Act and TOLA. Moreover, Sections 147 to 151

ASSISTANT COMMISSIONER OF INCOME TAX, KAUTILYA BHAWAN vs. JAJ INTERNATIONAL, MUMBAI

In the result, the grounds relating to merit the file of the Ld

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

reassess the income of the other person in ess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is accordance with the provisions of section 153A, if, that Assessing Officer is accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE- 41(1)(1), MUMBAI, KAUTILYA BHAWAN, BKC vs. JAJ INTERNATIONAL, MUMBAI

In the result, the grounds relating to merit the file of the Ld

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

reassess the income of the other person in ess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is accordance with the provisions of section 153A, if, that Assessing Officer is accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents

GAMNARAM OKHAJI PRAJAPATI ,MUMBAI vs. DCIT. CIRCLE 1(2)(1), MUMBAI

Appeal is allowed

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

151 of the new regime before passing an order under Section 148A(d) or issuing a notice under Section 148. 7 Assessment Year 2016-2017 (b) Under new regime if income escaping assessment is more than Rupees 50 lakhs a reassessment

CYRUS PATEL ,MUMBAI vs. INCOME TAX OFFICER WARD 23(2)(1), MUMBAI

In the result, the appeal is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

reassessment are issued beyond the period of three years from the end of the 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

ACIT-19(3), MUMBAI, MUMBAI vs. RISHABH AVNISH MODY, MUMBAI

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

151 of the new regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. 8.2 Under new regime, if income escaping assessment is more than Rupees 50 lakhs, a reassessment

INCOME TAX OFFICER (IT)-3(2)(1), KAUTILYA BHAWAN vs. SHAPOORJI PALLONJI MISTRY, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawal

reassess under unamended section 147, (b) issuance of notice under unamended section 148, (c) in accordance with time limit in terms of unamended section 149 and (d) sanction under unamended section 151

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -5 (3), MUMBAI, MUMBAI vs. ADITYA BIRLA SUN LIFE INSURANCE COMPANY LIMITED, MUMBAI

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

151 of the new regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. 8.2 Under new regime, if income escaping assessment is more than 13 ITA Nos. 3624-3625-4987-4822/Mum/ 2025 Aditya Birla Sun Life Insurance Co. Ltd. Rupees 50 lakhs, a reassessment

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 5(3), MUMBAI, MUMBAI vs. ADITYA BIRLA SUN LIFE INSURANCE COMPANY LIMITED, MUMBAI

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

151 of the new regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. 8.2 Under new regime, if income escaping assessment is more than 13 ITA Nos. 3624-3625-4987-4822/Mum/ 2025 Aditya Birla Sun Life Insurance Co. Ltd. Rupees 50 lakhs, a reassessment

ADITYA BIRLA SUN LIFE INSURANCE COMPANY LIMITED,MUMBAI vs. ASSESSMENT UNIT, ITD (JAO: DEPUTY COMMISSIONER OF INCOME-TAX, 5(3), MUMBAI), MUMBAI

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

151 of the new regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. 8.2 Under new regime, if income escaping assessment is more than 13 ITA Nos. 3624-3625-4987-4822/Mum/ 2025 Aditya Birla Sun Life Insurance Co. Ltd. Rupees 50 lakhs, a reassessment

ADITYA BIRLA SUN LIFE INSURANCE COMPANY LIMITED,MUMBAI vs. ASSESSMENT UNIT, ITD (JAO: DEPUTY COMMISSIONER OF INCOME-TAX, 5(3), MUMBAI), MUMBAI

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

151 of the new regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. 8.2 Under new regime, if income escaping assessment is more than 13 ITA Nos. 3624-3625-4987-4822/Mum/ 2025 Aditya Birla Sun Life Insurance Co. Ltd. Rupees 50 lakhs, a reassessment

SHIVI MUKESH KUMAR ,MUMBAI vs. ACIT, CIRCLE 22(1), MUMBAI

In the result, the appeal is partly allowed as indicated above

Bench: Shri Saktijit Dey & Shri Jagadishshivi Mukesh Kumar Acit, Circle 22(1) D-1402, Hubtown Seasons, Mumbai Next To Fine Arts Society, Vs. Ramakrishna Chemburkar Marg, Chembur, Mumbai-400 071 Pan/Gir No. Aqapk 9881 H (Appellant) : (Respondent) Appellant By : Shri Dharan V. Gandhi – Advocate & Ms. Vinita A. Nara – Advocate Respondent By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 11.12.2025 Date Of Pronouncement : 17.12.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against The Order Dated 01.07.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Assessment Year (A.Y.) 2016-17. 2. Though, The Assessee Has Raised Multiple Grounds, However, At The Time Of Hearing, Ld. Counsel Appearing For The Assessee Specifically Drew Our Attention To Ground No. 6, Which Reads As Under: 6. The Sanction U/S. 151 Is Bad In Law & As A Result, The Reassessment Proceeding Is Bad In Law. 3. Referring To This Ground, Ld. Counsel Submitted, At The Very Outset, This Issue May Be Considered And, If Warranted The Other Issues Can Be Taken Up Thereafter. As Could Be Seen

151 of the new regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. 8.2 Under new regime, if income escaping assessment is more than Rupees 50 lakhs, a reassessment

AJAY MULTI PROJECTS PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE 4(1)(1), MUMBAI, AAYKAR BHAWAN, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Ajay Multi Projects Pvt. Ltd., Dcit, Circle-4(1)(1), 2Nd Floor, C.J. House, 285 Aayakar Bhavan, Vs. Princess Street, Marine Lines, Mumbai-400020. Mumbai-400002. Pan No. Aadca 0338 H Appellant Respondent

section 148A have not been followed and as a result, the reassessment proceedings are bad in law. as a result, the reassessment proceedings are bad in law. as a result, the reassessment proceedings are bad in law. The sanction u/s 151

DEVANSHI SHARMA ,MUMBAI vs. ITO WARD 34(1)(1), MUMBAI

In the result, the appeal is allowed as indicated above

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.

151 of the new regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. (b) Under the new regime, if income escaping assessment is more than Rupees 50 lakhs, a reassessment

LEELABEN KANTILAL PAREKH,MUMBAI vs. INCOME TAX OFFICER WARD 20(2)(1), PIRAMAL CHAMBER, MUMBAI

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

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

151 have to be complied with. These procedural requirements are relatable either to the nature of the original assessment order [whether it was passed under section 143(3) or section 147 or whether it was passed otherwise] and how much period has elapsed between the passing of the original assessment order and initiation of reassessment

SHIVRAM S SHETTY,MUMBAI vs. INCOME TAX OFFICER WARD 2(1), THANE

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

reassessment notice under Section 148;\nd. The TOLA would extend the time limit for the grant of sanction by the authority\nspecified under Section 151