ASST. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3, SURAT vs. SHRI PIYUSH RANCHHODBHAI PATEL, SURAT

ITA 175/SRT/2022Status: DisposedITAT Surat20 August 2026AY 2013-201418 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Revenue failed to demonstrate compliance with the mandatory prior approval requirement under Section 153D. Consequently, the assessment orders were quashed.

What were the facts?

Following a search operation, assessment orders were passed for AYs 2011-12, 2012-13, and 2013-14. The assessee raised additional grounds challenging the validity of these orders due to non-compliance with Section 153D.

What were the issues?

Whether assessment orders passed without valid prior approval under Section 153D are sustainable and whether the Revenue discharged its burden to prove compliance.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Appellant: Shri Akshay M. Modi, CA
For Respondent: Shri Aashish Pophare, CIT (DR)
Hearing: 16.06.2026Pronounced: 20.08.2026

Per B.M. Biyani, AM:

The captioned six cross-appeals, consisting

The order continues below.

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