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    <title>2025 (11) TMI 1831 - ITAT DELHI</title>
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    <description>ITAT Delhi held that the approval granted u/s 153D was invalid as it was accorded through a single composite order covering 51 cases for multiple assessment years, including the assessee&#039;s AYs 2011-12 to 2017-18. Relying on the HC ruling in MDLR Hotels (P) Ltd., the Tribunal observed that such blanket approvals, without specific reference to records or seized material examined, are mechanical and lack proper application of mind. It noted the impracticality of examining 51 assessment records in one day. Consequently, the assessments framed by the AO on the basis of this defective approval were vitiated and stood quashed, allowing the assessee&#039;s appeal on this ground.</description>
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      <title>2025 (11) TMI 1831 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782363</link>
      <description>ITAT Delhi held that the approval granted u/s 153D was invalid as it was accorded through a single composite order covering 51 cases for multiple assessment years, including the assessee&#039;s AYs 2011-12 to 2017-18. Relying on the HC ruling in MDLR Hotels (P) Ltd., the Tribunal observed that such blanket approvals, without specific reference to records or seized material examined, are mechanical and lack proper application of mind. It noted the impracticality of examining 51 assessment records in one day. Consequently, the assessments framed by the AO on the basis of this defective approval were vitiated and stood quashed, allowing the assessee&#039;s appeal on this ground.</description>
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      <pubDate>Thu, 31 Jul 2025 00:00:00 +0530</pubDate>
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