AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
2026 (4) TMI 901
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....peal. But, at the time of hearing, Ld. AR for the assessee has filed an Application for admission of common additional grounds of appeal in all the 03 appeals. Since common grounds/additional grounds have been raised in all these appeals, hence, we are dealing with the facts of ITA No. 4454/Del/2025 (AY 2017-18) being the lead case. 2. The following are common additional grounds have been raised in AY 2017-18 :- 1. That the Ld CIT(A) erred in law in upholding the impugned assessment order passed under section 153C of the Act when the AO has sought common approval u/s. 153D for the AY 2013-14 to 2019-20 and which also was granted by the Ld. Addl. CIT by a common letter for all the assessment years from 2013-14 to 2019-20 purely i....
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....rateek Chitkara was not present at the premises and the proceedings were conducted in the presence of Mr. Shiv employee of Prateek Chitkara. During search action, 10 spiral diaries were found, seized and marked as Annexure A-1 to A-10. There were various cash entries in the said diaries which appeared to be relating to the cash committees and various other entries of cash received from and paid to various persons. Statement of Sh. Shiv was recorded on oath u/s. 132(4) of the Act on 8.12.2018 and he admitted that the entries in the diaries, marked as Annexure A-1 to A-10 seized from the said premises are relating to the cash committees being controlled and run by Prateek Chitkara and he also elaborated the procedure how the cash committees w....
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...., both on facts and in law in upholding the impugned assessment order passed u/s. 153C of the Act which was without valid jurisdiction, bad in law and was liable to be quashed inasmuch as the AO assumed jurisdiction u/s. 153C on the basis of a single, consolidated and mechanical "satisfaction note" common for all the assessment years, without recording a proper, independent and case-specific satisfaction for each assessment year separately and without establishing any linkage of seized material to the specific year under assessment, as mandated under section 153C rendering the assumption of jurisdiction fundamentally flawed and the resultant assessment orders void ab initio. 6. The Ld. DR of the Revenue relied upon the orders of the auth....
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....aft orders and finds that it meets the requirement of the law. As explained in the above cases the mere repeating of the words of the statute, or mere rubber stamping of the letter seeking sanction by using similar words like see or approved will not satisfied the requirement of law." 7.2 We further find that in the case of Pr. Commissioner of Income Tax -15 v. Shiv Kumar Nayyar the Hon'ble Delhi High Court held that : "17" Notable, the order of approval dated 30-12-2020 which was produced before us by the learned counsel for the assessee clearly signifies that a single approval has been granted for AYs 2011-12 to 2017- 18 in the case of the assessee. The said order also fail to make any mention of the fact that the draft assessment orde....
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.... Pronounced in the Open Court on 20/03/2026. ============= Document 1 Office of the Addl. Commissioner of Income Tax Central Range-02 Room No 341 E-2 ARA Centre 3rd floor Jhandewalan Extn. New Delhi- 110055 Email - [email protected] Tel. No. 011-23593414/Fax 011-23593413 F. No. Addl. CIT(CR)-02/2022-23/237 Dated: 30.03.2023 To The Dy. Commissioner of Income Tax, Central Circle-8, New Delhi Sub: Approval u/s 153D of the Income Tax Act, 1961 in the case Sh. Gaurav Verma (PAN: ABTPV5743R)- Reg. This is in reference to your letter F.No DCIT/CC-8/2022-23/1048 dated 29.03.2023 whereby you have submitted draft order to be passed seeking approval u/s 153D of the I.T. Act 1961 alongwith assessment record in the fo....