Finality of Section 153D approval bars reopening where prior departmental challenge already ended against the Revenue.

The validity of approval under Section 153D of the Income-tax Act, 1961 could not be reopened because its invalidity had already attained finality in the Department's earlier appeal. The approval was described as a common and composite order in the assessee's case, and that prior determination meant the present challenge no longer survived for adjudication. The Court left open, for consideration in appropriate proceedings, the question relating to Section 144A of the Income-tax Act, 1961 and the Search and Seizure Manual, 2007. The appeal was dismissed, and the challenge to the Section 153D approval failed.

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Issues: Whether the validity of approval under Section 153D of the Income-tax Act, 1961 could be reopened in the present appeal.

Analysis: The approval under Section 153D was stated to be a common and composite order in the respondent-assessee's case, and its invalidity had already attained finality in the Department's earlier appeal, which had been dismissed. In view of that prior final determination, the present challenge did not survive for adjudication. The Court kept open the question concerning Section 144A of the Income-tax Act, 1961 and the Search and Seizure Manual, 2007 for consideration in appropriate proceedings.

Conclusion: The appeal was dismissed, and the challenge to the approval under Section 153D failed.

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