Common Approval u/s 153D for Multiple Years Held Invalid – Search Assessment Quashed – ITAT Delhi

NV Distilleries Pvt. Ltd. Vs DCIT (ITAT Delhi) The assessee challenged the validity of assessment framed pursuant to search proceedings by raising additional legal grounds before ITAT questioning the legality of approval granted u/s 153D. The Tribunal admitted the additional grounds as they were purely legal issues going to the root of the matter, relying on the Supreme Court ruling in NTPC Ltd. vs. CIT. On facts, the AO had obtained a common approval from the Addl. CIT covering multiple assessment years through a single communication issued on the same date. The Tribunal observed that such co...