This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) orders pronounced between July and August 2026, each of which engages Section 151(ii) of the Income Tax Act, 1961 in the context of reassessment proceedings under Sections 147 and/or 148. The compilation is designed for in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citation-ready reference to recent tribunal activity on the sanction/approval requirement for reopening assessments. All cases are drawn from the TaxNoticeAI structured legal corpus and are presented in reverse-chronological order of pronouncement date.

Research index only. This page is a structured case-law reference and does not constitute legal advice. Readers must verify each ruling against the full judgment text and check for any subsequent stays, reversals, or appeals before relying on it.

The statutory framework in one paragraph

Section 151 of the Income Tax Act, 1961 prescribes the authority competent to sanction the issuance of a notice for reassessment of income. Broadly, the provision distinguishes between cases where the relevant assessment year has expired within four years from the end of the relevant assessment year and cases where it has expired beyond that period, requiring approval from different specified authorities depending on the time elapsed and the regime (pre- or post-Finance Act 2021 amendment). Section 151(ii), in particular, addresses the approval requirement applicable in specified circumstances under the reassessment framework, and non-compliance with this approval condition has been raised as a jurisdictional ground for challenging reassessment notices across a large number of ITAT proceedings in recent years.

The 12 rulings

1. Sumit Aggarwal ,Delhi vs ITO Ward 36 (1) , New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 6 August 2026
Sections engaged: 142(1), 148, 148A(b), 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed an appeal against the order of the learned CIT(A) NFAC, Delhi dated 12.03.2026 under Section 250 of the Income Tax Act, 1961. A primary ground raised by the assessee was that the notice issued under Section 148 of the Act was issued without obtaining approval from the specified authority as required under Section 151(ii) of the Act (ITA No. 4169/Del/2026, Assessment Year 2018-19, PAN: CLHPS0503E). The source preview does not disclose the tribunal's final holding on this ground.

2. Chandra S Sabhapathi,Shimoga vs Income Tax Officer, Ward-1, Shivamogga

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 4 August 2026
Sections engaged: 148A(d), 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed by the assessee challenging the order of the NFAC, Delhi dated 12/06/2025, with the matter concerning Assessment Year 2018-19 (ITA No. 1944/Bang/2025, PAN: BIVPC4752R). The appeal engages the validity of proceedings under Section 148A(d) and the approval requirement under Section 151(ii); the source preview does not contain the tribunal's substantive ruling on the merits of the challenge.

3. Shanovi Infrastructure Private vs Income Tax Officer, Ward 3(1), Raipur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 31 July 2026
Sections engaged: 148, 151(i), 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal preferred by the assessee emanates from an order relating to Assessment Year 2017-18 (ITA No. 301/RPR/2026, PAN: AAOCS5417Q), and engages both Section 151(i) and Section 151(ii) alongside Section 148 of the Act. The source preview confirms the appeal was heard on 29.07.2026 and pronounced on 31.07.2026, but does not disclose the tribunal's substantive findings on the approval grounds.

4. ITO, Piramal Chamber, Mumbai vs Karan Raju Jumani, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 31 July 2026
Sections engaged: 148, 151(2), 151(i), 151(ii), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter involves a Revenue appeal (ITA 2114/MUM/2026) and a cross-objection (CO 218/MUM/2026), both for Assessment Year 2016-17 (PAN: AAEPJ3831C). The text preview contains a partial reproduction of a table setting out the time-limit and specified-authority framework under the old reassessment regime, indicating that the applicable approval authority under the regime in force was a central issue. The source preview does not disclose the tribunal's final determination.

5. Upesh Dhirajlal Shah,Mumbai vs Income Tax Officer Ward 41(3)(4)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 30 July 2026
Sections engaged: 148, 151(2), 151(i), 151(ii), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 756/MUM/2026, Assessment Year 2016-17, PAN: AAFPS8899C) was filed by the assessee against the Income Tax Officer, Ward 41(3)(4). The text preview contains a partial reproduction of a time-limits/specified-authority table referencing Section 151(2) in the context of the "before expiry of four years" threshold, suggesting that the identity of the competent sanctioning authority was a contested issue in these proceedings. The source preview does not contain the tribunal's final ruling.

6. Omni Infoword Private Limited,Delh vs Dy. Commissioner Of Income Tax, Circle -

Bench: Income Tax Appellate Tribunal - Delhi
Date: 29 July 2026
Sections engaged: 132, 132A, 133A, 147, 148(d), 148A(a), 148A(b), 151(i), 151(ii), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee's appeal (ITA 2970/DEL/2026, Assessment Year 2017-2018, PAN: AAACO6799F) was directed against the order of the CIT(A)/NFAC, New Delhi dated 16.01.2026. The text preview includes a partial reproduction of a table contrasting the specified authority requirements under Section 151(2) (Joint Commissioner, before expiry of four years) and Section 151(1) (Principal Chief Commissioner or Chief Commissioner, after expiry of four years) of the old regime, indicating that the distinction between these approval tiers was a substantive issue in the proceedings. The source preview does not disclose the tribunal's final holding.

7. M/S. Leela Lace Holdings Private vs DCIT, Circle 2(2)(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 28 July 2026
Sections engaged: 147, 148, 148A, 148A(d), 149(1), 151(ii), 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed this appeal against the order of the NFAC Delhi passed under Section 250 of the Act dated 17.11.2025 (ITA 362/MUM/2026, Assessment Year 2016-17, PAN: AAACL0553A). The proceedings engage Section 151(ii) alongside Section 148A(d) and Section 149(1), indicating that both the approval requirement and the limitation period for issuing reassessment notices were in dispute. The source preview does not disclose the tribunal's substantive findings.

8. Harish Bansal,Delhi vs DCIT, Circle 25(1), Delhi, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 27 July 2026
Sections engaged: 148A(b), 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: These were twin appeals (ITA Nos. 1386/Del/2026 and 8302/Del/2025) for Assessment Years 2014-15 and 2016-17 respectively (PAN: AEZPB1361G), arising against CIT(A)/NFAC Delhi orders dated 13.06.2025 and 28.11.2025, involving reassessment proceedings. The source preview confirms that the appeals were heard on 29.06.2026 and pronounced on 27.07.2026, with the Section 151(ii) approval requirement raised alongside Section 148A(b); the preview does not disclose the tribunal's substantive holding.

9. Vijaya Raj,Chennai vs Income Tax Officer,Non Corporate

Bench: Income Tax Appellate Tribunal - Chennai
Date: 16 July 2026
Sections engaged: 148, 151(ii), 148A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 470/CHNY/2026, Assessment Year 2017-18, PAN: ATWPS8442F) was filed by the assessee against the Income Tax Officer, Non-Corporate Ward - 19(6), Chennai. Per the source preview, it was submitted that the notice under Section 148 of the Act was issued beyond a period of three years from the end of the relevant assessment year, engaging the Section 151(ii) approval threshold applicable in such cases. The source preview does not disclose the tribunal's final ruling.

10. A Kalyanasundaram,Trichy vs ITO, Ward-1(1), Trichy

Bench: Income Tax Appellate Tribunal - Chennai
Date: 10 July 2026
Sections engaged: 148, 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 2408/Chny/2026, Assessment Year 2018-19, PAN: BTOPK8895B) was filed against the order dated 20.11.2025 of the CIT(A), National Faceless Appeal Centre, Delhi, arising out of the assessment order dated 19.03.2024 passed by the Assessment Unit, National Faceless Assessment Centre, Delhi. The appeal engages Section 148 and Section 151(ii); the source preview does not disclose the tribunal's substantive findings.

11. Swift Developers,Mumbai vs Income Tax Officer (Au), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 10 July 2026
Sections engaged: 148, 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: Three consolidated appeals (ITA Nos. 3225, 3226, and 3227/MUM/2026, each for Assessment Year 2017-18, PAN: ABEFS2386L) were filed by the assessee against the Income Tax Officer (AU), Mumbai. The appeals engage Section 148 and Section 151(ii) and were heard on 11/06/2026 with the order pronounced in open court on 10/07/2026. The source preview does not contain the tribunal's substantive findings on the Section 151(ii) ground.

12. ITO, Ward 3(1), Hyderabad vs Smark Securities Limited, Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 8 July 2026
Sections engaged: 147, 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed this appeal (I.T.A. No. 2200/Hyd/2025, Assessment Year 2018-19, PAN: AACCS6948J) against the order of the CIT(A), National Faceless Appeal Centre, Delhi dated 07/10/2025; a cross-objection (CO No. 8/Hyd/2026) was also filed by the assessee. The appeal engages Section 147 and Section 151(ii), with the Revenue challenging the CIT(A)'s order; the source preview does not disclose the tribunal's substantive findings on the Section 151(ii) issue.

Patterns across these 12 rulings

Section 151(ii) raised as a jurisdictional ground across all 12 matters. Every case in this compilation includes Section 151(ii) in its sections list, confirming that the approval/sanction requirement for reassessment notices is being systematically raised as a threshold challenge at the ITAT level across multiple benches (Delhi, Mumbai, Bangalore, Chennai, Raipur, Hyderabad) during the July–August 2026 period.
Frequent co-occurrence of Section 148 / 148A with Section 151(ii). The large majority of these cases also cite Section 148 and/or Section 148A (or its sub-clauses), confirming that Section 151(ii) challenges arise in close conjunction with challenges to the issuance and validity of reassessment notices — rather than as standalone grounds.
Both pre- and post-amendment reassessment regimes engaged. Several cases in this compilation (cases 4, 5, and 6 in particular) reference the time-limit/specified-authority table distinguishing between the old regime thresholds and the approval authority applicable, indicating that parties are litigating the identity of the correct sanctioning authority under both the pre- and post-Finance Act 2021 frameworks.
National Faceless Appeal Centre (NFAC) orders are the immediate trigger in most cases. Across the majority of these appeals, the assessee or Revenue is appealing before the ITAT against a CIT(A)/NFAC order — indicating that the Section 151(ii) approval ground is being pressed and decided at first appeal level and is then carried further to the ITAT.
Outcome data is unavailable for all 12 cases in the source corpus. None of the twelve orders provide a disclosed outcome or reasoning in the available text previews, which are largely confined to procedural and caption-level information. Researchers should access the full text of each judgment from the primary source portals to determine the tribunal's substantive holding.

How to use this compilation

This index is intended as a starting point for locating relevant ITAT orders on the Section 151(ii) approval requirement in reassessment proceedings. Because all twelve source previews in the underlying corpus are limited to procedural and caption-level text, the substantive holdings of each tribunal are not reproduced here. Researchers must retrieve the full text of each judgment — by ITA number, bench, and date — from indiankanoon.org, the official ITAT website, or other authorised court portals before drawing any conclusions about ratio decidendi, the scope of the ruling, or its applicability to a specific fact pattern.

Before placing reliance on any of these orders, researchers should verify: (a) whether any stay, rectification, or further appeal has been filed or decided subsequent to the pronouncement date noted in this compilation; (b) whether CBDT has issued any circular, instruction, or press release that may affect the interpretation of Section 151(ii) in the relevant time-period; and (c) whether there is a co-ordinate bench or higher court ruling on the same or similar facts that may take precedence.

The coverage window for this compilation is July–August 2026. Because ITAT orders are pronounced on a continuous basis, researchers working on a specific matter should conduct an independent search of recent orders to ensure they have a complete picture of the current state of tribunal opinion on the Section 151(ii) approval requirement.

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(ii) Approval for Reassessment: 12 ITAT Rulings (2026)