Section 151(i) of the Income Tax Act

The decision most relied on for Section 151(i) is Micro Marbles Pvt. Ltd. v. ITO (457 ITR 569), cited in 11 of the 37 judgments on BharatTax that turn on this section.

Leading authorities on Section 151(i)

Judgments on Section 151(i)

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

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

ITA 5293/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Dec 2025AY 2016-17

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

For Appellant: Shri Dharan V. Gandhi – Advocate &For Respondent: Shri Arun Kanti Datta – CIT DR
Section 133ASection 143(3)Section 147Section 148Section 151Section 35(1)(ii)

IVA NARAYAN,KOLKATA, WEST BENGAL vs. ITO, WARD 3(1), MALDA, WEST BENGAL, KOLKATA, WEST BENGAL

In the result, appeal of the assessee is allowed

ITA 1246/KOL/2025[2016-17]Status: DisposedITAT Kolkata21 Nov 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddyआयकर अपील सं/Ita No.1246/Kol/2025 ("नधा"रण वष" / Assessment Year : 2016-2017) Iva Narayan Vs Ito Ward-3(1), Malda 2B, Vishnu Niwas, 220 Nsc Bose Road, Kolkata West Bengal-700047 Pan No. :Aadcb 5095 Q (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Akash Ojha, Ar राज"व क" ओर से /Revenue By : Shri Mrinmay Basak, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 13/10/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/11/2025 आदेश / O R D E R The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 14.05.2025 Passed For Assessment Year 2016-2017. 2. At The Outset, Ld. Ar Submitted That The Assessment Framed By The Ao U/S.147 R.W.S.144B Of The Act Is Not Sustainable As The Notice Issued U/S.148 Of The Act Is Barred By Limitation. The Ld.Cit(A) Also Without Considering The Same Dismissed The Appeal Of The Assessee. It Was The Submission Of The Ld.Ar That Notice U/S.148 Of The Act Was Issued On The Assessee On 20.07.2022. Ld. Ar Drew My Attention To Notice Issued U/S.148 Of The Act, Copy Of Which Has Been Filed At Page 8 Of The Paper Book. Ld. Ar Further Submitted That The Impugned Assessment Year Is A.Y.2016-2017. It Was The Submission That Notice Issued U/S.148 Of The Act Was Issued As A Consequence Of The Judgment Of The Hon’Ble Supreme Court In The Case Of Ashish Agarwal, Reported In (2022) 444 Itr

For Appellant: Shri Akash Ojha, ARFor Respondent: Shri Mrinmay Basak, Sr. DR
Section 147Section 148

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Section 151(i) of the Income Tax Act — Case Laws | BharatTax