Mechanical 153D Approval Vitiates Entire 153A Block – Delhi ITAT  

Dileep K. Gupta Vs DCIT (ITAT Delhi)

In this batch of six appeals arising from search assessments u/s 153A r.w.s. 143(3), Assessee challenged the very validity of the assessments on the ground that approvals u/s 153D were issued mechanically by the JCIT, Central Range-8. ITAT examined the approval letters   &  order-sheet notings , noting that no assessment folders, seized material, investigation report, or records were ever forwarded to the JCIT; only the draft orders were sent on 28.03.2022/30.03.2022. Despite this, the JCIT issued approvals on 29.03.2022 & 31.03.2022

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