2025 (7) TMI 114

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....19-20 arising out of the appeal before it against the order dated 31.12.2019 passed u/s 153A r.w.s. 143(3) of the Income Tax Act, 1961 (hereinafter referred as 'the Act') by the ACIT, Central Circle- 14, New Delhi (hereinafter referred to as the Ld. AO). The assessee has filed Cross Objections. 2. Heard and perused the records. Assessee raises an additional ground which is reproduced below; "1. That having regard to the facts and circumstances of the case, Ld. C1T(A) ought to have quashed the impugned assessment order passed by Ld.AO u/s 153A without obtaining approval under section 153D in accordance with law and without complying with the mandatory conditions laid down under that section." 3. As the additional ground raised....

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..... 153D of the Act. In view of the aforesaid factual matrix, we find considerable cogency in the contention of the Ld. AR that exactly on similar facts and circumstances of the case, the Coordinate Bench vide its common order dated 10.01.2025 passed in another case viz. Prateek Nagpal (supra) similar legal issue was decided in favour of the assessee by quashing the entire proceedings initiated under section 153C r.w.s. 153A of the Act in the absence of a valid approval granted by the ACIT, Central Range-4, New Delhi. 8. Notably, the order of approval dated 30.12.2020 reproduced establishes that a single approval has been granted for various assessment years and various assessee. The said order also fails to make any mention of the fact th....

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....012-13 to 2018-19 153A/153C/143(3) 7. Sh. Prem Parkash Sethi AQIPS3728H 2012-13 to 2018-19 153A/153C/143(3) 8 Sh. Pankaj Sethi ABKPS5373B 2012-13 to 2018-19 153A/153C/143(3) 9 Sh. Deepak Sayal AAAPS5887M 2012-13 to 2018-19 153A/153C/143(3) 10 M/s Shiv Vani Buildcon pvt. Ltd. AAPCS0835B 2012-13 to 2018-19 153A/153C/143(3) 11 Sh. Sachin Kumar BUWPK8443E 2012-13 to 2018-19 153A/153C/143(3) 12 Sh. Abheek Nagpal AMTPN9992M 2012-13 to 2018-19 153A/153C/143(3) Document 2 Smt. Sharda Rani Sethi AZTPS1702R 2018-19 153A/153C/143(3) 5 14 Priya Sethi CEOPS7016E 2018-19 153A/153C/143(3) 15 Smt. Sangeeta Sayal AAUPS2763G 2012-13 to 2018-19 153A/153C/143(3) 16 Sahana Kumar AZZPK3408J 2018-19 153A/153C/143(3) 17 Rahul Say....