SHRI JATIN MADANI ,DELHI vs. ACIT CENTRAL CIRCLE-06 , DELHI

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ITA 6136/DEL/2025Status: DisposedITAT Delhi20 July 2026AY 2014-153 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the approval under Section 153D must be accorded separately for each assessment year, even for a single assessee. Since the approval provided was common for multiple years, it was deemed invalid.

What were the facts?

The assessee filed appeals against assessment orders for AYs 2013-14, 2014-15, and 2017-18. The primary contention was that the assessments were invalid due to a lack of proper approval under Section 153D of the Income-tax Act.

What were the issues?

The key issue was the validity of assessments made under Section 153A without separate, year-specific approval under Section 153D.

Which sections of the Income-tax Act were involved?

Section 153A,Section 143(3),Section 153D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘H’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI KRINWANT SAHAY

Hearing: 14.07.2026Pronounced: 14.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘H’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER ITA Nos.6135, 6136 & 6137/Del/2025 Assessment Years: 2013-14, 2014-15 & 2017-18 Sh. Jatin Madani, Vs. ACIT, F-14/50, 2nd Floor, Model Central Circle-06, Town Part 2, Dr. Mukherjee Delhi Nagar, North West Delhi, Delhi -110 009 PAN: ASBPM1649J (Appellant) (Respondent) Assessee by Sh. Akash Ojha, Adv. Department by Sh. Bhopal Singh, CIT(DR) Date of hearing 14.07.2026 Date of pronouncement 14.07.2026 ORDER PER SATBEER SINGH GODARA, JM These assessee’s three appeals ITA Nos. 6135, 6136 & 6137/Del/2025 for assessment year 2013-14, 2014-15 & 2017-18, arise against the Commissioner of Income Tax (Appeals)-24 [in short, the “CIT(A)”], New Delhi’s orders, all dated 28.08.2025 passed in cases no. CIT(A), Delhi-24/10407/2018-19, 10409/2018-9 & 10429/2018-19, involving proceedings under

ITA Nos.6135 to 6137/Del/2025

section 153A r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. Heard both the parties. Case file perused. 2. It emerges at the outset that the assessee herein canvasses its first and foremost legal ground seeking to annul the impugned section 153A r.w.s. 143(3) assessments framed on 31.12.2019 in all three assessment years 2013-14, 2014-15 and 2017-18 for want of a valid approval under section 153D of the Act. 3. We have given our thoughtful consideration to the assessee’s and the Revenue’s respective vehement contentions regarding the first and foremost issue of validity of the impugned assessments as lacking valid approval under section 153D of the Act. The assessee has filed the learned prescribed authority’s common approval dated 30.12.2018 granted in his seven cases for assessment years 2011-12 to 2017-18. Various recent judicial precedents i.e. PCIT Vs. Anuj Bansal, (2024) 165 taxmann.com 2 (SC), PCIT Vs. Subodh Agrawal (2023) 149 taxmann.com 373 (Allahabad), PCIT Vs. Sapna Gupta (2023) 147 taxmann.com 288 (Allahabad), PCIT Vs. Siddarth Gupta (2023) 147 taxmann.com 305 (Allahabad), PCIT Vs. Shiv Kumar Nayyar (2024) 467 ITR 186 (Del.), PCIT Vs. Anuj

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ITA Nos.6135 to 6137/Del/2025

Bansal (2024) 466 ITR 254 (SC) and PCIT Vs. MDLR Hotels (P.) Ltd. (2024) 166 taxmann.com 327 (Del.) have already settled the issue in assessee’s favour and against the department that such an approval under section 153D has to be accorded separately for each and every assessment years even if it involves a single assessee. We thus accept the assessee’s instant first and foremost legal ground/argument to quash the impugned assessments herein framed by the Assessing Officer on 30.12.2018 in assessment years 2013-14, 2014-15 & 2017-18 in very terms.

All other pleadings on merits herein stand rendered academic. 5. These assessee’s three appeals ITA Nos. 6135, 6136 to 6137/Del/2025 are allowed in above terms. A copy of this common order be placed in the respective case files. Order pronounced in the open court on 14th July, 2026 Sd/- Sd/- (KRINWANT SAHAY) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 20th July, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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