This compilation indexes twelve rulings from the Income Tax Appellate Tribunal (ITAT) across multiple benches — Surat, Mumbai, Delhi, Ranchi, Cuttack, Amritsar, Ahmedabad, and Jaipur — in which Section 151(1) of the Income-tax Act, 1961 was engaged, either as a standalone ground or alongside reassessment provisions such as Sections 147 and 148. The rulings span the period from June 2020 to August 2026 and are drawn from the TaxNoticeAI structured legal corpus. This index is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need to quickly survey how ITAT benches have framed Section 151(1) disputes across different factual contexts and assessment years.

Research index only. This page is a structured case-law reference. Nothing on this page constitutes legal advice, tax advice, or any form of professional opinion. Readers should verify all rulings against the full text of the original judgment before relying on them in any proceeding or filing.

The statutory framework in one paragraph

Section 151(1) of the Income-tax Act, 1961 requires that before a notice for reassessment is issued under Section 148, the Assessing Officer must obtain the prior approval or sanction of a specified authority. The identity of the "specified authority" whose sanction is required depends on the time elapsed since the end of the relevant assessment year: different tiers of authority are prescribed for cases falling within four years and those falling beyond four years from the end of the assessment year. The sanction under Section 151(1) is a mandatory jurisdictional prerequisite, and its absence or formal deficiency has been repeatedly raised as a ground for challenging the validity of reassessment proceedings before the ITAT.

The 12 rulings

1. Harshit Traders,Surat vs The Income Tax Officer, Ward 3(3)(1)

Bench: Income Tax Appellate Tribunal - Surat
Date: 5 August 2026
Sections engaged: 147, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the ITAT Surat Bench as ITA No.1344/SRT/2025, concerning Assessment Year 2012-13, by a registered partnership firm engaged in the business of diamonds commission agency. Per the source preview, the assessee's transactions involved purchase and sales figures that were identical in value, described as being for statistical purposes only. The substantive grounds, including any challenge to the sanction under Section 151(1), are not further detailed in the available preview.

2. Namgyal Lechcho,Mumbai vs Income Tax Officer, Wd-19(2)(4)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 27 July 2026
Sections engaged: 143(3), 147, 148, 151(1), 282A, 282A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal, filed as ITA 1984/MUM/2026 for Assessment Year 2020-21, was directed against the order of the National Faceless Appeal Centre (NFAC), Delhi. Ground No. 1 raised by the assessee specifically challenged the sanction granted under Section 151(1) as invalid on the ground that it did not contain the signature of the specified authority, i.e., the PCIT. The Tribunal noted, per the source preview, that it had heard counsel for both parties and perused the material placed on record, though the final determination is not captured in the available preview.

3. Income Tax Officer, Delhi vs Jimmy Talwar, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 22 July 2026
Sections engaged: 148, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed by the Revenue as ITA No. 738/Del/2026, directed against the order of the Commissioner of Income Tax (Appeals), NFAC, Delhi dated 27/11/2025 for Assessment Year 2016-17. Per the source preview, the assessee had originally filed a return declaring income of Rs. 3,90,470/- after claiming exemption on account of long-term capital gain from sale of equity shares of M/s Panafic Industrials Ltd., with the return having been processed under Section 143(1). The subsequent reassessment proceedings and the Section 151(1) related grounds are not further detailed in the available preview.

4. Hiteshbhai Rameshbhai Patel,Surat vs ITO Ward,2, Bardoli, Bardoli

Bench: Income Tax Appellate Tribunal - Surat
Date: 23 December 2025
Sections engaged: 147, 148, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 484/SRT/2025 before the ITAT Surat Bench (SMC), concerning Assessment Year 2012-13, and was directed against the order of the Commissioner of Income-tax (Appeals). Per the source preview, the case involved multiple cash deposit transactions in the assessee's account totalling Rs. 41,40,000/-, the details of which were tabulated in the order. The grounds relating to the validity of the reassessment and the Section 151(1) sanction are not further elaborated in the available preview.

5. Hiralal Agencies Pvt. Ltd.,,Ranchi vs DCIT, Circle-1, Ranchi

Bench: Income Tax Appellate Tribunal - Ranchi
Date: 20 November 2025
Sections engaged: 147, 148, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal, filed as I.T.A. No. 288/RAN/2024, arose against the order of NFAC, Delhi dated 24.05.2024, which in turn arose from an order of the Assessing Officer passed under Section 147 read with Section 144 of the Income-tax Act, 1961 for Assessment Year 2011-12. Per the source preview, the assessee had filed a return of income declaring a total income of ₹1,78,71,900/-, and the case was selected for scrutiny. The hearing was conducted virtually at Kolkata, and the Section 151(1) grounds are not further elaborated in the available preview.

6. Hirakhand Transport And Multi Purpose vs Income Tax Officer, Ward-1

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 4 September 2024
Sections engaged: 40A(2)(b), 147, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter came before the ITAT Cuttack Bench as ITA No.282/CTK/2024 along with a Cross Objection No.04/CTK/2024, both arising from Assessment Year 2015-2016. Per the source preview, the appeal involved grounds relating to transactions with contractors who were described as related parties of the assessee, engaging Section 40A(2)(b) alongside the reassessment provisions. The Section 151(1) ground and the final determination are not further detailed in the available preview.

7. M/S Chotti Leasing & Finance Pvt. Ltd vs DCIT, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 23 January 2023
Sections engaged: 147, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter involved a consolidated bunch of appeals by the Revenue — ITA Nos. 6211, 6212, 6213, and 6214/DEL/2015 — covering Assessment Years 2007-08, 2008-09, 2009-10, and 2010-11, along with corresponding Cross Objections filed by the assessee. Per the source preview, the matter was heard on 19.01.2023 and pronounced on 23.01.2023. The substantive grounds, including the Section 151(1) challenge, are not further elaborated in the available preview.

8. Shri Sardari Lal, S.B.S Nagar vs Income Tax Officer Ward Nawanshahar

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 16 August 2021
Sections engaged: 148, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA Nos. 588 to 590/Amr/2019, covering Assessment Years 2009-10 to 2011-12. Per the source preview, the case involved tabulated figures relating to undisclosed sales, gross profit estimated at 8%, income disclosed in returns, and balance undisclosed profit across three successive assessment years. The Section 151(1) related grounds and the final determination are not further detailed in the available preview.

9. Shri Omprakash Kanayalal Shah vs ITO, Ward-6(1)(5), Ahmedabad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 4 June 2021
Sections engaged: 148, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee was in appeal before the Tribunal against the order of the CIT(A)-6, Ahmedabad for Assessment Year 2010-11. Per the source preview, the Assessing Officer had issued a notice under Section 148, which was stated to have been issued on 30.3.2017 and served upon the assessee; in response, the assessee filed a return of income on 23.9.2017 declaring total income of Rs. 94,010/-. The assessee's first ground of appeal challenged the validity of the reassessment proceedings, including the Section 151(1) sanction, though the final determination is not captured in the available preview.

10. Karan Khurana , Delhi vs ITO, Ward- 48(2), New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 17 March 2021
Sections engaged: 147, 148, 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 1783/Del./2019 for Assessment Year 2010-2011, directed against the order of CIT(A)-16, New Delhi dated 07.01.2019. Per the source preview, the assessee's grounds specifically alleged that the impugned reassessment order was passed without providing a copy of the reasons recorded along with the satisfaction note of the approving authority under the relevant provision of the IT Act, despite a specific request made by the appellant during the assessment proceedings, and therefore the resultant reassessment order was claimed to be non-est and liable to be quashed. A further ground alleged that the reassessment was invalid and without jurisdiction as it was completed without complying with legal requirements.

11. Shri Yogesh Sharma, 61-B, Sahakar vs ITO, Ward-4(1), Jaipur, Ward-4(1)

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 16 September 2020
Sections engaged: 151(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 455/JP/2019 before the ITAT Jaipur Bench for Assessment Year 2009-10. Per the source preview, the case involved a detailed examination of cash withdrawal and deposit transactions in the assessee's account across various dates, with a running cash balance tabulated in the order. Section 151(1) was the sole section cited, and the specific grounds raised and the final determination are not further elaborated in the available preview.

12. Tulip Global Pvt. Ltd.C/O- Shri Vinod vs DCIT, Circle-3, Jaipur, Circle-3

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 30 June 2020
Sections engaged: 151(1), 133A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 614/JP/2019 before the ITAT Jaipur Bench for Assessment Year 2010-11, directed against the order dated 26.02.2019 of CIT(A), Alwar. Per the source preview, the assessee raised as many as 8 grounds, but at the time of hearing the authorised representative confined the argument only to the issue of validity — which the source preview indicates was a central contested point — with the Section 151(1) sanction being engaged alongside Section 133A. The hearing was concluded through video conference in view of the prevailing COVID-19 pandemic situation, and the final determination is not further detailed in the available preview.

Patterns across these 12 rulings

Section 151(1) raised as a jurisdictional/procedural threshold ground. Across multiple cases in this compilation — most explicitly in Cases 2, 10, and 12 — the validity of the Section 151(1) sanction is raised at the threshold, before the substantive merits of reassessment are addressed. This pattern reflects an established litigation strategy of challenging the jurisdictional prerequisites of reassessment as a preliminary ground.
Frequent co-occurrence of Sections 147, 148, and 151(1). The majority of cases in this compilation engage Sections 147, 148, and 151(1) together (Cases 3, 4, 5, and 10), reflecting the interlocked procedural chain: a reason to believe under Section 147, a notice under Section 148, and a mandatory prior sanction under Section 151(1). A challenge to any one link in this chain frequently appears as a ground in the same appeal.
Absence of signature of the specified authority as a specific invalidity ground. Case 2 (Namgyal Lechcho) expressly raises the absence of the PCIT's signature on the Section 151(1) sanction as a distinct ground of invalidity. This formalistic but jurisdictionally significant challenge to the mechanics of the sanction — rather than its substantive sufficiency — represents a recurring theme in post-amendment reassessment litigation.
Non-supply of reasons and satisfaction note as a linked ground. Case 10 (Karan Khurana) illustrates the related but distinct challenge of the assessee not being provided the reasons recorded for reopening and the satisfaction note of the approving authority despite a specific request, with the assessee contending that this rendered the reassessment non-est. This procedural non-disclosure ground frequently accompanies the Section 151(1) sanction challenge.
Wide geographic and temporal spread with no appellate authority uniformity visible from previews. The 12 rulings span benches in Surat, Mumbai, Delhi, Ranchi, Cuttack, Amritsar, Ahmedabad, and Jaipur, and cover assessment years ranging from 2007-08 to 2020-21. Because the outcome field is not specified in the source for any case in this compilation, no uniform directional pattern (assessee-favour vs. revenue-favour) can be responsibly stated. Researchers should consult the full text of each judgment.

How to use this compilation

This compilation is structured as a first-pass research index, not a substitute for reading the full judgment. Each case entry provides the bench, date, sections engaged, and outcome direction as extracted from the TaxNoticeAI corpus, along with a procedural note grounded strictly in the available source preview. Before citing any ruling in a brief, representation, or filing, researchers should retrieve the complete order from the relevant official court portal (indiankanoon.org, the ITAT's own e-filing portal, or the relevant High Court website) and verify the holding, operative paragraph, and any subsequent stay or reversal.

Researchers should also check whether any of the rulings listed here have been challenged in appeal before the High Court or the Supreme Court, or whether the relevant High Court has expressed a view on the same question in a binding precedent for that jurisdiction. The ITAT is not a court of record for the purposes of creating binding precedent across benches, and divergent views between benches on Section 151(1) questions are not uncommon.

Finally, CBDT circulars and instructions issued from time to time may affect how the Section 151(1) sanction requirement is operationalised in practice, including the identity of the "specified authority" for different time-bar categories. Researchers should check for any relevant CBDT circular or instruction contemporaneous with the assessment year under examination, as the statutory scheme has been amended and the prescribed authority has changed across different legislative versions of the provision.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 151(1) Sanction for Reassessment: 12 ITAT Rulings (2020–2026)