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    <title>2025 (12) TMI 1689 - ITAT DELHI</title>
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    <description>The dominant issue was the validity of approval under s. 153D, where a single approval was accorded for 14 assessment years covering two assessees. Applying HC authority that s. 153D approval is mandatory and justiciable, the Tribunal held that although elaborate reasons are not required, the approval must reflect application of mind, including indication of examination of draft orders and relevant seized material. As the approval letter was merely ritualistic, with no reference to seized material or demonstrable involvement of the approving authority, the approval was held mechanical, vitiating the assessments. Consequently, the assessment orders were quashed and the appeals were allowed.</description>
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    <pubDate>Fri, 24 Oct 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1689 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784149</link>
      <description>The dominant issue was the validity of approval under s. 153D, where a single approval was accorded for 14 assessment years covering two assessees. Applying HC authority that s. 153D approval is mandatory and justiciable, the Tribunal held that although elaborate reasons are not required, the approval must reflect application of mind, including indication of examination of draft orders and relevant seized material. As the approval letter was merely ritualistic, with no reference to seized material or demonstrable involvement of the approving authority, the approval was held mechanical, vitiating the assessments. Consequently, the assessment orders were quashed and the appeals were allowed.</description>
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      <pubDate>Fri, 24 Oct 2025 00:00:00 +0530</pubDate>
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