Section 151 → Section 284

Sanction for issue of reassessment notice

Section 151 of the old Income-tax Act, 1961 · new section 284 under the Income-tax Act, 2025

New reference Section 284

Income-tax Act, 1961Section 151

Specified authority for 148 and 148A: Additional/Joint Commissioner or Additional/Joint Director
Single level of approval since 1 September 2024
Before that, PCCIT/PCIT approval was needed for older years
Approval challenges ('mechanical sanction') were common in litigation

Applies to FY 2025-26 (AY 2026-27) and earlier years.

Income-tax Act, 2025Section 284

Section 284: Additional Commissioner, Additional Director, Joint Commissioner or Joint Director
Same authority for notices under sections 280 and 281
Section 522(3) (FA 2026): approvals for assessment/reassessment are administrative and not invalid for insufficient reasons or authentication defects
Applies from 1 April 2026

Applies from tax year 2026-27 (from 1 April 2026).

What changed

Same sanctioning authority. The real change is in section 522(3), which narrows challenges based on defective or mechanical approvals.

Practice notes

For notices on years governed by the 1961 Act, the sanction rules in force on the date of notice apply; see transition provisions in section 536.

These are summaries, not the statutory text. Read the bare Act for both sections on the Income Tax Department's official site, which also has a side-by-side comparison utility.

Frequently asked

Who approves reassessment notices under the new Income Tax Act?

The Additional/Joint Commissioner or Additional/Joint Director under section 284 of the Income-tax Act, 2025.

What is section 151 called in the new Income-tax Act, 2025?

Section 151 of the Income-tax Act, 1961 corresponds to Section 284 of the Income-tax Act, 2025, which applies from 1 April 2026 (tax year 2026-27).

What changed in section 151 under the new Income Tax Act?

Same sanctioning authority. The real change is in section 522(3), which narrows challenges based on defective or mechanical approvals.

Is section 151 still applicable for FY 2025-26?

Yes. Income of FY 2025-26 (AY 2026-27) and earlier years is governed by section 151 of the 1961 Act. Section 284 of the 2025 Act applies from tax year 2026-27.

Related sections

149→282Time limit for reassessment notices (148) and show-cause notices (148A)148→280Notice for reassessment where income has escaped assessment, and the pre-notice procedure 282–298→501–536Service of notice, SFT, CbCR, authorised representative, rounding off, 292B, rules and repeal