This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) orders pronounced between 31 August 2026 and 11 September 2026, each engaging Section 151(i) of the Income Tax Act, 1961 — the provision governing the identity of the "specified authority" required to sanction reassessment notices under the new regime where three years or less have elapsed from the end of the relevant assessment year. The rulings span multiple ITAT benches (Mumbai, Chennai, Rajkot, Ahmedabad, Chandigarh, and Varanasi) and cover Assessment Years ranging from 2016-17 to 2019-20. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for locating and cross-referencing recent ITAT activity on the Section 148/151(i) sanction-authority question.

Research index only — not legal advice. This page catalogues publicly available ITAT orders for research and reference purposes. Nothing on this page constitutes legal, tax, or professional advice. Readers must consult the full text of each judgment and qualified advisers before relying on any ruling.

The statutory framework in one paragraph

Section 151 of the Income Tax Act, 1961 (as substituted with effect from 1 April 2021 by the Finance Act, 2021) prescribes the "specified authority" whose prior sanction is mandatory before a notice for reassessment under Section 148 can be issued. The section bifurcates into two sub-provisions based on the time elapsed from the end of the relevant assessment year: Section 151(i) applies where three years or less than three years have elapsed, and Section 151(ii) applies where more than three years have elapsed. Under Section 151(i) of the new regime, the specified authority is the Principal Commissioner or Principal Director or Commissioner or Director. Under Section 151(ii) of the new regime, the specified authority is the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. These requirements operate independently of — and in contrast to — the old-regime sanction structure under the erstwhile Sections 151(1) and 151(2), which drew the authority line at the four-year mark from the end of the relevant assessment year. The mapping of the correct regime and the correct specified authority to the particular assessment year under scrutiny is the recurring procedural flashpoint across the rulings collected below.

The 12 rulings

1. Mohammed Hasseb Mohammed Hanif vs Income Tax Officer Ward - 34(2)(1)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 11 September 2026
Sections engaged: 147, 148, 148A, 148A(a), 148A(b), 148A(d), 151(1), 151(2), 151(i), 151(ii), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Mumbai as ITA 4713/MUM/2026 for Assessment Year 2018-19 (PAN: AQMPM9595J). The text preview reproduces a comparative table of sanction authorities under both the old and new regimes, indicating that the Tribunal was required to identify which regime and which specified authority applied to the reassessment proceedings under challenge; the substantive analysis and final direction are not discernible from the source preview.

2. Jwc Logistics Park Private vs ACIT Cc 5(3), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 11 September 2026
Sections engaged: 148, 151(1), 151(2), 151(i), 151(ii), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Mumbai as ITA 3017/MUM/2026 for Assessment Year 2018-19 (PAN: AACCJ4231E). The text preview sets out the comparative sanction-authority table under both the old and new regimes, indicating that the central question before the Tribunal involved the identification of the correct specified authority for the reassessment notice issued under Section 148; the final direction is not discernible from the source preview.

3. Jobanputra Charitable Trust,Mumbai vs ACIT Cc 5(3), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 11 September 2026
Sections engaged: 147, 148, 148A(b), 148A(d), 151(1), 151(2), 151(i), 151(ii), 3(1), 45
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Mumbai as ITA 3011/MUM/2026 for Assessment Year 2018-19 (PAN: AAATJ0329F). The text preview reproduces the same regime-wise sanction-authority matrix seen in contemporaneous Mumbai Bench F orders, indicating the Tribunal was examining the validity of the sanction obtained before issuance of the reassessment notice; the final direction of the order is not discernible from the source preview.

4. Jagadhaeswaran vs Assessing Officer, Coimbatore

Bench: Income Tax Appellate Tribunal - Chennai
Date: 10 September 2026
Sections engaged: 148, 148A, 148A(a), 148A(b), 151(1), 151(2), 151(i), 151(ii), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Chennai 'C' Bench as ITA No. 2309/CHNY/2026 for Assessment Year 2017-18 (PAN: AKKPV3545R). The text preview reproduces a regime-wise mapping of time limits and specified authorities, indicating that the Tribunal was called upon to determine whether the sanction obtained prior to issuance of the reassessment notice complied with the applicable sub-provision of Section 151; the final direction of the order is not discernible from the source preview.

5. Bapa Sitaram Coal,Morbi vs Income Tax Officer, Ward 1, Morbi, Morbi

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 10 September 2026
Sections engaged: 148, 148A(b), 148A(d), 149, 149A(c), 149A(d), 151(i), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Rajkot as ITA No. 680/Rjt/2026 for Assessment Year 2017-18 (PAN: AAQFB7958J). Per the source preview, the assessee had e-filed a return of income for AY 2017-18 on 07.11.2017, declaring total income of Rs. 18,16,310/-, and the Assessing Officer thereafter received credible information from the office of the ADIT (Inv.), Unit-4, Surat, which formed the basis for the reassessment proceedings; the final direction of the order is not discernible from the source preview.

6. Vidhi S Khandelwal,Mumbai vs Income Tax Officer, Ward 42(1)(5)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 9 September 2026
Sections engaged: 147, 148, 148A, 151(1), 151(2), 151(i), 151(ii), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Mumbai as ITA 4215/MUM/2026 for Assessment Year 2017-18 (PAN: AJTPK3619B). The text preview reproduces the comparative regime-wise sanction-authority table, indicating the Tribunal examined whether the specified authority condition under the applicable sub-provision of Section 151 was satisfied before the reassessment notice was issued; the final direction of the order is not discernible from the source preview.

7. Jayesh Jain,Ahmedabad vs The Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 9 September 2026
Sections engaged: 132, 143(1), 144B, 147, 147A, 148, 148A, 148A(b), 149(1), 151(i), 151(ii), 153(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Ahmedabad 'B' Bench as ITA No. 718/AHD/2026 for Assessment Year 2019-2020 (PAN: ADIPJ7605D). Per the source preview, the assessee's appeal was directed against the order dated 15/01/2026 passed by the National Faceless Appeal Centre (NFAC), Delhi, which had dismissed the appeal against an assessment order dated 10/03/2025 passed under Section 147 read with Section 144B of the Act for Assessment Year 2019-2020; the final direction of the ITAT order is not discernible from the source preview.

8. Shaktikumar Sureshchandra vs ITO Wd 3(1)(1), Rajkot, Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 8 September 2026
Sections engaged: 10(38), 142(1), 147, 148, 151(i), 151(ii), 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Rajkot as ITA No. 414/RJT/2025 for Assessment Year 2017-18 (PAN: ALJPV5257E). Per the source preview, the case was reopened under Section 147 read with Section 148 on the basis of information available with the Department that the financial transactions carried out by the assessee in the scrip of GBFL and Ejecta Marketings Ltd. were under scrutiny; the final direction of the order is not discernible from the source preview.

9. Somil Exim Llp,Surat vs Income Tax Officer- 19(3)(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 8 September 2026
Sections engaged: 144B, 147, 148, 148A, 148A(d), 151(i), 151(ii), 250, 254
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Mumbai 'B' Bench as ITA No. 6450/Mum/2026 for Assessment Year 2017-18 (PAN: ACTFS9023N). Per the source preview, the appeal was directed against the order dated 11.03.2026 passed by the National Faceless Appeal Centre, Delhi under Sections 250 and 254 of the Act, and the assessee raised various grounds challenging both the validity of the reassessment proceedings and the additions made by the Assessing Officer; the final direction of the order is not discernible from the source preview.

10. John Roase Veda Singh Air Packia vs ITO, Ward-1,, Nagercoil

Bench: Income Tax Appellate Tribunal - Chennai
Date: 1 September 2026
Sections engaged: 148, 149, 151(i), 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Chennai 'B' Bench as ITA No. 1552/Chny/2026 for Assessment Year 2018-19 (PAN: AEHPA6716). Per the source preview, the appeal was directed against the order dated 05.03.2026 of the learned Commissioner of Income Tax (Appeals), NFAC, Delhi, arising out of an assessment order dated 07.09.2023 passed under Section 147 of the Act; the final direction of the ITAT order is not discernible from the source preview.

11. Devinder Kumar Singla,Chandigarh vs Income Tax Officer, Ward-2(1)

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 1 September 2026
Sections engaged: 132, 132A, 133A, 135A, 139, 147, 148, 148A, 149, 151(i), 151(ii), 90
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Chandigarh 'A' Bench as ITA No. 170/Chandi/2026 (along with C.O. No. 18/Chandi/2026) for Assessment Year 2016-17 (PAN: AJAPS-2131-F). Per the source preview, the revenue's appeal arose from a CIT(A)/NFAC order dated 19.11.2025 in the matter of an assessment framed under Section 147 read with Section 144B on 23.05.2023, where the sole grievance of the revenue was that the assessment order had been quashed by the CIT(A); the final direction of the ITAT order is not discernible from the source preview.

12. Yashwant Kumar,Mau vs Income Tax Officer, Ward 3(3), Mau

Bench: Income Tax Appellate Tribunal - Varanasi
Date: 31 August 2026
Sections engaged: 142(1), 144B, 147, 148, 148A, 151(i), 194H
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before ITAT Varanasi 'DB' Bench as ITA No. 8/VNS/2025 for AY 2017-18 (PAN: CZMPK1553M). Per the source preview, the appeal was against the CIT(A)/NFAC order dated 04.06.2024 dismissing the assessee's challenge to the assessment order passed under Section 147 read with Section 144B for AY 2017-18 dated 29.03.2022; the source preview also notes that the appeal before the Tribunal was delayed by 157 days and was accompanied by a condonation petition.

Patterns across these 12 rulings

Uniform engagement of the old-regime/new-regime sanction-authority matrix. Every ruling in this compilation engages both Section 151(i) and Section 151(ii) (and, in several cases, the old-regime Sections 151(1) and 151(2) as well), indicating that the Tribunals are routinely required to map the applicable regime — based on years elapsed from the end of the relevant assessment year — before evaluating whether the sanction condition was met. This comparative framework appears verbatim across multiple Mumbai Bench F orders pronounced on the same date.
Assessment Years 2017-18 and 2018-19 dominate the docket. Nine of the twelve rulings involve Assessment Years 2017-18 or 2018-19. This clustering reflects the time-sensitivity of reassessment windows under the new regime introduced from 1 April 2021, and the consequent rush of challenges reaching the appellate stage in 2025-2026.
NFAC orders as the immediate antecedent. Multiple appeals in this set (cases 7, 9, 10, 11, and 12) were directed against orders of the National Faceless Appeal Centre (NFAC), Delhi, confirming that the NFAC layer is the standard first appellate forum through which Section 151(i) sanction disputes pass before reaching the ITAT.
Section 147 read with Section 144B as the assessment vehicle. Across several rulings (cases 7, 9, 11, and 12), the impugned assessment was framed under Section 147 read with Section 144B, indicating that faceless reassessment procedure is now the predominant mode in which the sanction-authority question under Section 151(i) arises.
Absence of discernible final directions in source previews. All twelve rulings carry the outcome designation "Outcome not specified in source," which means the dispositive direction — whether the reassessment was upheld, quashed, or remanded — cannot be extracted from the available previews. Researchers must access the full text of each order to determine the final holding.

How to use this compilation

This compilation is structured as a research index, not a digest of holdings. Because the outcome field for all twelve rulings is recorded as "Outcome not specified in source," readers should treat the entries above as identification and procedural-context cards only. The first step in any research workflow should be to retrieve the full text of each order from indiankanoon.org or the official ITAT portal using the ITA numbers provided in the source previews (e.g., ITA 4713/MUM/2026, ITA No. 680/Rjt/2026, ITA No. 718/AHD/2026, ITA No. 8/VNS/2025). Full-text review is essential to confirm the bench's final direction, any remand instructions, and whether the sanction defect — if found — was treated as curable or fatal to the reassessment.

Readers should also verify whether any of these orders have been subsequently stayed, appealed to the jurisdictional High Court, or reversed. ITAT orders are not binding precedent on other benches and carry persuasive value only; conflicting views across benches on the Section 151(i) sanction-authority question are common and should be checked against the latest High Court and Supreme Court decisions on the point. Additionally, CBDT instructions and circulars issued after 1 April 2021 regarding the operationalisation of the new reassessment regime may bear on the interpretation of "specified authority" and should be consulted alongside the case law.

Finally, note that several rulings in this set involve concurrent or cross-referenced proceedings (e.g., the cross-objection in case 11, and the citation of a separate ITA number in case 7's preview). Researchers working on a specific assessee's file should map all connected proceedings — ITA, cross-objection, writ, and any CBDT instruction references — before forming a view on the current status of the sanction-authority issue in that file.

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 148 Reassessment & Section 151(i) Sanction: 12 ITAT Rulings (2026)