Omnibus Section 153D Approval = Fatal Jurisdictional Defect – Entire Group Assessments Quashed

N V Distilleries Pvt. Ltd. Vs DCIT (ITAT Delhi) ITAT Delhi quashed search assessments for AYs 2015-16 to 2018-19 in the NV Distilleries / NV Distilleries & Breweries group, holding that the mandatory approval u/s 153D was granted in a mechanical and omnibus manner, vitiating jurisdiction itself. The Addl. CIT granted a single, common approval dated 31.12.2019 for multiple assessees and multiple assessment years. The approval letter merely stated that approval is accorded “on the basis of discussions held from time to time”, without any reference to examination of seized material, appra...