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One-Size-Fits-All Approval Invalid – Absence of Mindful 153D Approval Vitiates Entire Assessment
Case Law Details
- Case Name
- Melody Enterprises Pvt. Ltd. Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2016-17
- Courts
- All ITAT, ITAT Delhi
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Melody Enterprises Pvt. Ltd. Vs ACIT (ITAT Delhi)
Background
Search & seizure: Conducted u/s 132 at premises of Shri Deepak Agarwal, Shri Mukesh Kumar & others, wherein documents relating to assessee were seized.
Assessment: Order passed on 24.12.2018 u/s 143(3) r.w.s. 153A, making additions.
CIT(A) (28.10.2022): Dismissed assessee’s appeal.
Before ITAT: Assessee challenged legality of assessment on ground that approval u/s 153D was mechanical & perfunctory, hence assessment void.
Tribunal’s Observations
1. Nature of Approval u/s 153D
Approval letter (24.12.2018) from Addl. ...
Author Info
