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    <title>2025 (12) TMI 260 - ITAT, DELHI</title>
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    <description>ITAT Delhi allowed the assessees&#039; additional legal ground and held the impugned assessments under s.153A to be non est in law due to invalid approval under s.153D. The JCIT had issued common, omnibus approvals covering multiple assessees and assessment years, without distinct taxpayer-wise and year-wise satisfaction, which was found to be contrary to the statutory mandate of s.153D. As this jurisdictional defect vitiated the very foundation of the assessments, all consequential assessment orders were quashed, and the remaining grounds on merits were treated as academic.</description>
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    <pubDate>Wed, 30 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 260 - ITAT, DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782720</link>
      <description>ITAT Delhi allowed the assessees&#039; additional legal ground and held the impugned assessments under s.153A to be non est in law due to invalid approval under s.153D. The JCIT had issued common, omnibus approvals covering multiple assessees and assessment years, without distinct taxpayer-wise and year-wise satisfaction, which was found to be contrary to the statutory mandate of s.153D. As this jurisdictional defect vitiated the very foundation of the assessments, all consequential assessment orders were quashed, and the remaining grounds on merits were treated as academic.</description>
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