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Judgment
Per Satbeer Singh Godara, Judicial Member:
This assessee’s appeal for Assessment Year 2013-14, arises against the CIT(A)-24, New Delhi’s DIN & order No. ITBA/APL/S/250/2025-26/1082064606(1) dated 28.10.2025, in proceedings u/s 153A r.w.s. 143(3) of the Income Tax Act, 1961 (in short “the Act”).
Heard both the parties at length. Case file perused.
We next note that there arises the first and foremost issue of validity of the impugned asse ssments framed u/s 153A r.w.s. 143(3) of the Act; dated 24.06.2021, in conse quence to the search action herein dated 12-13.03.2019 on the ground that the learned prescribe d author ity had not accorded a valid approval there to u/s 153D of the Act.
It is in this factual backdrop that we note with the able assistance co ming from both the parties that the learned Assessing Officer had sought the prescribed authority’s approval dated 01.06.2021 i.e. a common one for six assessment years fro m 2013-14 to 2018-19 which stood granted in very terms; and therefore, we quote PCIT Vs. Shiv Kumar Nayyar (2024) 163 taxmann.com 9 (Del.), PCIT Vs. MDLR Hotels (P) Ltd. (2024) 166 taxmann.com 3 27 (Del.) and ACIT vs. Ser ajuddin and Co. (2024) 163 taxmann.com 118 (SC), to conclude that such a 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 asse ssment year 2013-14 in ve ry terms.
All other pleadings on merits herein stand rendered academic.
This assessee’s appeal is allowed in above terms.