2026 (6) TMI 285

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....the Income Tax Act, 1961 (the Act) dated 26.11.2025 pertaining to AYrs 2004-05 to 2010-11) respectively. 2. The issues involved in all the appeals are common, interlinked and related to the same assessee, therefore, they have been heard together and accordingly, adjudicated by this common order. 3. First, we take assessee's appeal in ITA No. 748/Del/2026 for AY 2004-05. 4. The assessee in its appeal has taken as many as 7 grounds, but he only argued the legal ground which reads as under:- "5. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of AO in passing the impugned assessment order dated 21.12.2021 without there being requisite approval in....

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....o 45/2022 held that: "22. As rightly pointed out by learned counsel for the assessee there is not even a token mention of the draft orders having been perused by the Additional CIT. The letter simply grants an approval. In other words even the bare minimum requirement of the approving authority having to indicate what the thought process involved was is missing in the aforementioned approval order. While elaborate reasons need not be given, there has to be some indication that the approving authority has examined the draft 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 w....

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....herefrom to quash all the impugned assessments framed herein in assessee's case in assessment years 2004-05 to 2010-11 in very terms. 10. As a result, the assessee's quantum appeals being ITA Nos. 748 to 754/Del/2026 (Ayrs. 2004-05 to 2010-11) involving the corresponding impugned assessment succeed. 11. To sum up, these assessee's 07 appeals ITA Nos. 748 to 754/Del/2026 are allowed. A copy of this common order be placed in the respective case files. Order pronounced in the open Court on 15.05.2026. ============= Document 1 Office of the Addl. Commissioner of Income Tax, Central Range-4, 3rd Floor. A.R.A. Centre, E-2 , Jhandewalan Extn. New Delhi-110075 F.No./Addl. CIT/ C.R-4/91/2011 12/574 Dated 24 -12-2011 To, The Assistan....