ITAT Invalidates Consolidated Section 153D Approval for 28 Assessees

Gokul Kumar Vs ACIT (ITAT Delhi)

Single Consolidated 153D Approval for 28 Assessees Invalid— No Independent Application of Mind—All Assessments Quashed

Assessee filed appeals for ten consecutive AYs arising from search assessments framed u/s 153A r.w.s. 143(3). The core legal ground raised was that the assessments were void due to invalid approval u/s 153D. Tribunal examined the record and noted that AO forwarded only draft assessment orders on 30.12.2019 seeking approval. The Addl. CIT issued one single consolidated approval for

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