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Judgment
Per Satbeer Singh Godara, Judicial Member:
These assessee’s seven appeals in ITA Nos. 5685 to 5691/Del/2025 for Assessment Years 2015-16 to 2021-22, arise against the CIT(A)-28, Delhi’s DIN & order Nos. ITBA/APL/S/250/2025-26/1079099147(1), 1 079099486(1), 1079099884(1), 1079100226(1), 1 079199531(1), 1079537557(1) & 1079581658(1) dated 30.07.2025, 12.08.2025 & 13.08.2025, in proceedings u/s 153C r.w.s. 144 of the Income Tax Act, 1961 (in short “the Act”), respectively.
Heard both the parties at length. Case files perused.
We next note that there arises the first and foremost issue of validity of the impugned asse ssments framed u/s 153C r.w.s. 144 of the Act; dated 14.02.2024, in consequence to the search actio n herein dated 28.12.2020 on the ground that the learned prescribed authority had not accorded a valid approval thereto u/s 153D of the Act.
It is in this factual backdrop that we admit the assessee’s instant legal ground and note with the able assistance coming from both the parties that the learned Assessing Officer had sought the prescribe d authority’s common approval dated 23.01.2024. The clinching fact emanating from the approval letter is that the lear ned Assessing Officer her ein had infact sought a common approval for the assessee in seven assessment years fro m 2015-16 to 2021-22 which stood granted, and therefore, we quo te PCIT Vs. Shiv Kumar Nayyar (2024) 163 taxmann.com 9 (Del.), PCIT Vs. MDLR Hote ls (P) Ltd. (2024) 166 taxmann.co m 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 e ntire assessment itself. We draw strong support there from to quash the impugned assessments framed herein in assessee’s case in assessment years 2015-16 to 2021-22 in very terms.
All other pleadings on merits herein stand rendered academic.
These assessee’s seven appeals ITA Nos. 5685 to 5691/Del/2025 are allowed in above terms. A copy of this common order be placed in the respective case files.