Combined Mechanical Section 148B Approval for Six Assessees Quashed by ITAT Delhi

Reema Sharda Vs DCIT (ITAT Delhi) Combined Approval u/s 148B for Multiple Assessees is Mechanical—Following Earlier Sharda-Family Ruling, Assessments Quashed Both appeals were filed by Mrs. Reema Sharda (AY 2022-23) and Mrs. Mamta Sharda (AY 2021-22) challenging reassessment orders passed under the amended 148A/148B regime. The central legal issue raised was that the approval u/s 148B dated 23.05.2023—a single, common sanction issued for six different assessees—was mechanical, lacked application of mind, and therefore vitiated the entire reassessment process. The assessees pointed out th...