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    <title>2026 (4) TMI 392 - ITAT DELHI</title>
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    <description>Prior approval under section 153D must be granted separately for each assessment year and must show independent application of mind to the draft order and relevant material. A consolidated sanction for multiple years, without any indication of separate examination, is treated as mechanical compliance and fails the statutory safeguard. On that basis, the assessments founded on such common approval were quashed in favour of the assessee. The appeal succeeded on the jurisdictional objection, while the remaining grounds were not adjudicated and were left open.</description>
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    <pubDate>Fri, 27 Feb 2026 00:00:00 +0530</pubDate>
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      <description>Prior approval under section 153D must be granted separately for each assessment year and must show independent application of mind to the draft order and relevant material. A consolidated sanction for multiple years, without any indication of separate examination, is treated as mechanical compliance and fails the statutory safeguard. On that basis, the assessments founded on such common approval were quashed in favour of the assessee. The appeal succeeded on the jurisdictional objection, while the remaining grounds were not adjudicated and were left open.</description>
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