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    <title>2025 (11) TMI 898 - ITAT DELHI</title>
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    <description>Assessments framed under section 143(3) read with section 153A were challenged on the ground that approval under section 153D was not validly granted. The assessee was allowed to raise this legal ground in appeal because it went to the root of the matter and the relevant facts were already on record. The assessment records showed that one common approval had been sought and granted for multiple assessment years. Applying the principle that section 153D approval must be specific and valid for each assessment, the omnibus combined approval was treated as invalid and the assessments were quashed in favour of the assessee.</description>
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    <pubDate>Fri, 19 Sep 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 898 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=781430</link>
      <description>Assessments framed under section 143(3) read with section 153A were challenged on the ground that approval under section 153D was not validly granted. The assessee was allowed to raise this legal ground in appeal because it went to the root of the matter and the relevant facts were already on record. The assessment records showed that one common approval had been sought and granted for multiple assessment years. Applying the principle that section 153D approval must be specific and valid for each assessment, the omnibus combined approval was treated as invalid and the assessments were quashed in favour of the assessee.</description>
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      <pubDate>Fri, 19 Sep 2025 00:00:00 +0530</pubDate>
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