Alankit Insurance TPA Ltd. Vs DCIT (ITAT Delhi)
ITAT Delhi Quashes Sec 153C Proceedings – Consolidated Satisfaction & Mechanical Sec 153D Approval Held Invalid
In Alankit Insurance TPA Ltd. (AYs 2013-14 to 2020-21), the ITAT Delhi partly allowed the assessee’s appeals by quashing proceedings initiated u/s 153C. The Tribunal observed that the Assessing Officer recorded only a consolidated satisfaction note without demonstrating how seized material from the searched persons pertained to or had any bearing on the assessee’s income, which is mandatory for valid jurisdiction under Sec 153C.
Relying on judicial precedents including PCIT vs Siddharth Gupta and Delhi High Court rulings, ITAT held that approval u/s 153D must reflect independent application of mind and cannot be mechanical or omnibus for multiple assessment years. Since the statutory requirements were not properly fulfilled, the proceedings were held unsustainable and grounds of the assessee were allowed, while other issues were kept open.
FULL TEXT OF THE ORDER OF ITAT DELHI
The assessee has filed eight appeals against the separate orders passed by the Ld. Commissioner of Income-tax (Appeals)-25, Delhi (hereinafter referred to as “Ld. CIT(A)”), all dated 16.05.2025, for Assessment Years 2013-14 to 2020-21.
2. Since the issues involved in all the appeals are common and the appeals are interconnected, they were heard together and are being disposed of by this consolidated order. For the sake of convenience, ITA No. 3802/Del/2025 for Assessment Year 2014-15 is treated as the lead case.
