GAURAV VERMA,DELHI vs. DCIT, CENTRAL CIRCLE-8, DELHI

ITA 4455/DEL/2025Status: DisposedITAT Delhi20 March 2026AY 2018-19Bench: Sh. S. Rifaur Rahman, Accountant Member & Sh. Sudhir Kumar (Judicial Member)8 pages
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What did the Tribunal hold?

The Tribunal held that the approval obtained under Section 153D was invalid as it was a common approval for multiple assessment years, granted mechanically without due application of mind. This vitiates the entire assessment.

What were the facts?

A search and seizure operation was conducted, leading to the discovery of diaries containing cash entries. The Assessing Officer added an amount based on these entries and framed assessment orders under Section 153C. The assessee appealed these orders.

What were the issues?

Whether the common approval under Section 153D for multiple assessment years is valid and whether the assumption of jurisdiction under Section 153C is fundamentally flawed due to the invalid approval.

Which sections of the Income-tax Act were involved?

Section 153C,Section 153D,Section 132,Section 132(4),Section 69A

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, DELHI BENCH ‘B’, NEW DELHI

Before: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Adv. & Sh. Sudhir
For Respondent: Ms. Pooja Swaroop, CIT(DR)
Hearing: 26.02.2026Pronounced: 20.03.2026

Heard together (3 matters)

ITA No. 4454/Del/2025
ITA No. 4455/Del/2025
ITA No. 4456/Del/2025

Read from the judgment's own cause title. This page is filed under one of them.

Per Sudhir Kumar, Judicial Member:

The instant batch of 03 appeals pertains to the single assessee herein namely, Gaurav Verma, against the separate orders of the Ld. CIT(A)-24, New Delhi pertaining to assessment years 2017-18, 2018-19 & 2019-20 wherein, the assessee has raised various grounds of appeal. But, at the time of hearing, Ld. AR for the assessee has filed an Application for admission of common additional grounds of appeal in all the 03 appeals. Since common grounds/additional grounds have been raised in all these

appeals, hence, we are dealing with the facts of ITA No. 4454

The order continues below.

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