2026 (4) TMI 31

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....cer (hereinafter referred to as the Ld. AO, for short) passed u/s 153A/143(3) of the Income-tax Act, 1961 (hereafter referred to as 'the Act'). Further details of the orders of the lower authorities are as under:- ITA No. & AY Ld. FAA who passed the appellate order Appeal No. & Date of order of the Ld. FAA AO who passed the assessment order & Date of order 4465/D/25 2014-15 CIT(A)-3, Gurgaon Appeal No.CIT(A)/GGN- 3/10639/2013-14, 11068/2014- 15, 11249/2015-16, 11619/2016-17 dated 27.06.2025 ACIT, CC-1 Dated 18.09.2021 4466/D/25 2015-16 CIT(A)-3, Gurgaon Appeal No.CIT(A)/GGN- 3/10639/2013-14, 11068/2014- 15, 11249/2015-16, 11619/2016-17 dated 27.06.2025 ACIT, CC-1 Dated 18.09.2021 4467/D/25 2016-17 C....

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....lity and approval cannot be called mechanical approval as there was sufficient time between the request made for granting approval and the approval actually granted for which ld. DR has relied the copies of the letters written and it was submitted that while in regard to AY: 2014-15 letter dated 23.08.2021 was written in fact AY: 2015- 16 and 2017-18 letter dated 29.06.2021 was written and in regard to AY: 2016-17, 2018-19 & 2019-20 letter dated 31.08.2021 was written. 4. However, we go through this letters relied by ld. DR we find that these are not letters written seeking approval in regard to assessee alone but in assessee being part of M/s Piyush Group search assessments and case of assessee was also sent along. 5. Then, further w....

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....peals deserves to be sustained. The appeals are allowed and the impugned assessment are quashed. Order pronounced in the open court on 20.02.2026. ============= Document 1 OFFICE OF THE ADDL. COMMISSIONER OF INCOME TAX (CENTRAL RANGE), GURUGRAM 7º FLOOR, HSIIDC BUILDING, UDYOG VIHAR, PHASE-V, GURUGRAM Phone No - 0124-2450460, 2450051, Fax No - 2450097 estas.gov.In V. No. Addl. CIT (CH)/GGM/2021-22/ 376 Dated: 02.07.2021 To The Deputy Commissioner of Income Tax. Central Circle-1. Faridabad. . Sub: Approval u/s 153D of the Income Tax Act, 1961 In the case of Sh. Sanjay Gupta, PAN- AAZPG2141D for A.Y. 2013-14, 2015-16 & 2017- 18 - Regarding- 1. This is In reference to your letter No. 560 dated 29.06.2021 whereby yo....

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....n reference to your letter No. 894 dated 31.08.2021 whereby you have submitted draft orders to be passed seeking approval u/s 153D of the I.T. Act, 1961 in the case of Sh. Sanjay Gupta, PAN, AAZPG2141D for A.Y. 2016-17, 2018- 19 & 2019-20. 2. The approval u/s 153D of the IT Act, 1961, is accorded for A.Y. 2016-17, .. 2018-19 & 2019-20 considering the facts as submitted that Proper opportunity of being heard was provided to assessee. All the issues appearing from the material on record were duly examined and 3. Relevant copies of selzed documents were verified before passing the draft order. 3. It is further directed that order should be passed well before the limitation and copies of the final orders so passed be sent to this....