2025 (9) TMI 634

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....br>Income Tax<br>Sh. Satbeer Singh Godara, Judicial Member And Sh. M. Balaganesh, Accountant Member For The Assessee : Sh. Ajay Wadhwa, Adv. & Sh. Ujjawal Jain, Adv. For The Revenue : Sh. Subhash Kumar, Sr. DR ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: The instant batch of eight appeals pertains to the single assessee herein namely, Sh. Aditya Sharma. All other relevant details thereof ....

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....he search action herein dated 15.02.2014, on the ground that the learned prescribed authority had not accorded a valid approval thereto u/s 153D of the Act. The Revenue could hardly dispute that the instant legal ground sought to be raised at the assessee&#39;s behest goes to the root of the matter and therefore, we quote National Thermal Power Co. Ltd. vs. CIT (1998) 229 ITR 383 (SC); as consider....

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....stood granted, and therefore, we quote PCIT Vs. Shiv Kumar Nayyar (2024) 163 taxmann.com 9 (Del.), PCIT Vs. MDLR Hotels (P) Ltd. (2024) 166 taxmann.com 327 (Del.) and ACIT vs. Serajuddin and Co. (2024) 163 taxmann.com 118 (SC), to conclude that such a combined section 153D approval indeed vitiates the entire assessment itself. We draw strong therefrom to quash all the impugned assessments framed h....