Section 153C Assessment Quashed – Mechanical & Combined Approval U/s 153D Held Invalid

Poonam Lohia Vs ACIT (ITAT Delhi)

The ITAT Delhi allowed the assessee’s appeal and quashed the assessment framed u/s 153C for AY 2015-16 after admitting additional legal grounds challenging validity of approval u/s 153D. The Tribunal observed that the approval granted by the Addl. CIT was mechanical and showed clear non-application of mind, as the subject line of the approval letter itself omitted AY 2015-16 and a single combined approval was granted for multiple assessment years. Relying on judicial precedents including PCIT vs. Shiv Kumar Nay

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