ITAT Delhi Quashes 153C Assessment – One Approval for Two Years Held Invalid

Vivaan Prakash Vs DCIT (ITAT Delhi) Delhi Tribunal quashed the 153C assessment, holding that the approval u/s 153D issued by Addl. CIT, Lucknow, was mechanical & non-application of mind since it was a single approval for two assessment years. The Tribunal found the approval to be a pro forma sanction without reference to seized material or independent reasoning. Referring to PCIT v. Shiv Kumar Nayyar (Del HC), ACIT v. Serajuddin & Co. (Ori HC) & PCIT v. Sapna Gupta (All HC), it held that such ritualistic approval vitiates the assessment itself. Accordingly, the 153C order was decla...