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1 - 10 of 17 (0.24 seconds)Section 151 in The Income Tax Act, 1961 [Entire Act]
Section 153A in The Income Tax Act, 1961 [Entire Act]
Section 147 in The Income Tax Act, 1961 [Entire Act]
Section 260A in The Income Tax Act, 1961 [Entire Act]
Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 119 in The Income Tax Act, 1961 [Entire Act]
Parashuram Pottery Works Co. Ltd vs Income Tax Officer, Circle-1, Ward 'A', ... on 16 November, 1976
39. In Synfonia Tradelinks (P.) Ltd Vs Income Tax Officer,
Ward-22(4)12, the Delhi High Court held that the satisfaction
arrived at by the concerned officer must be discernible from
the sanction order passed under Section 151. A mere
endorsement that the information received from the
investigation wing and the reasons recorded by the AO
satisfied that the income had escaped taxation was not
sufficient to indicate the record of any proper satisfaction or
application of mind for the grant of approval.
Acit vs M/S. Serajuddin & Co. Kolkata on 15 March, 2023
In the case of ACIT Vs. Serajuddin and Co.1, the Orissa
High Court was concerned with prior approval of the superior
officer before an order of assessment or re-assessment is
passed pursuant to a search operation under Section 153D
read with Section 153A of the IT Act. The Court held that
such approval is mandatory and must not be given
mechanically. The Court explained that, while elaborate
reasons need not be given, there must be some indication that
the approving authority examined the draft orders and found
that they met the requirements of law. The Court held that
where approval was granted mechanically, it would vitiate the
assessment order itself. The Court also referred to the CBDT
guidelines for granting such approvals and noted that these
guidelines can be traced to Section 119 of the Income Tax Act,
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1961. The Court also noted that there was a series of
judgments about the instructions under Section 119 binding
the Department. The Special Leave Petition against this
decision was dismissed by the Hon'ble Supreme Court2.
Commissioner Of Income Tax, Jabalpur vs M/S. S. Goyanka Lime And Chemicals Ltd. on 23 March, 2015
The Special Leave Petition
against the decision in S. Goyanka Lime & Chemicals Ltd
(supra) was dismissed by the Hon'ble Supreme Court6.