AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
2026 (4) TMI 814
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.... 2. Since the issues involved in all the appeals are common and the appeals are interconnected, they were heard together and are being disposed of by this consolidated order. For the sake of convenience, ITA No. 3802/Del/2025 for Assessment Year 2014-15 is treated as the lead case. 3. At the time of hearing, the Ld. AR submitted that a search operation was carried out on 18.10.2019 in the cases of Shri Alok Kumar Agarwal, Shri Ankit Agarwal, Alankit Ltd. and Alankit Assignments Ltd. Based on the information and documents seized during the said search, the Assessing Officer recorded satisfaction under section 153C of the Income-tax Act, 1961, a copy of which is placed at page 83 of the paper book dated 24.12.2021. 4. It was further ....
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....he approval granted under section 153D of the Act is merely an administrative approval and that the procedure relating to such approval has no bearing on the assessee or the assessment proceedings. According to her, the approval process under section 153D is only an administrative requirement and does not confer any substantive right upon the assessee. She, therefore, relied upon the findings of the lower authorities. 8. We have considered the rival submissions and carefully perused the material available on record. We have specifically examined the approval granted under section 153D of the Act and the judicial precedents cited by the Ld. AR, as placed in the paper book and referred to during the course of hearing. We find that Hon'ble ....
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....irement of approval under Section 153D is pre-requisite to pass an order of assessment or re-assessment. Section 153D requires that the Assessing Officer shall obtain prior approval of the Joint Commissioner in respect of "each assessment year" referred to in Clause (b) of sub-section (1) of Section 153A which provides for assessment in case of search under Section 132. Section 153A(1)(a) requires that the assessee on a notice issued to him by the Assessing Officer would be required to furnish the return of income in respect of "each assessment year" falling within six assessment years (and for the relevant assessment year or years), referred to in Clause (b) of sub-section (1) of Section 153A. The proviso to Section 153A further p....
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....ge 36 of the paper book of the assessee. The said letter clearly states This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 20/05/2024 at 21:34:51 that a letter dated 30.12.2018 was filed by the ld. AO before the ld. Addl. CIT seeking approval of draft assessment order u/s 153D of the Act. The ld. Addl. CIT has accorded approval for the said draft assessment orders on the very same day i.e., on 30.12.2018 for seven assessment years in the case of the assessee and for seven assessment years in the case of Smt. NeetuNayyar. It is also pertinent in this regard to refer to pages 68 and 69....
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.... we cannot lose sight of the fact that in the instant case, the concerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above. 18. Therefore, under the facts of the present case, considering the foregoing discussion and the enunciation of law settled through This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 20/05/2024 at 21:34:51 judicial pronouncements discussed hereinabove, we are unable to find any substantial question of law which would merit our consideration." 10. We....