Combined Section 153D Approval covering Multiple Years Invalid: ITAT Delhi

DS Spiceco Pvt. Ltd. Vs DCIT (ITAT Delhi) The appeal concerns an assessment for AY 2015-16 completed under Section 153C read with Section 143(3) of the Income-tax Act. The assessee challenged the assessment on the ground that it lacked a valid approval under Section 153D. The Tribunal examined the material and noted that the approval dated 22.12.2021 was a common approval issued for seven assessment years from 2011-12 to 2017-18. Referring to judicial precedents, including Shiv Kumar Nayyar, Anuj Bansal, and MDLR Hotels, the Tribunal held that Section 153D requires a separate, year-specific ap...