SWIFT IMPEX PRIVATE LIMITED, NEW DELHI,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-27, NEW DELHI, NEW DELHI

ITA 4920/DEL/2025Status: DisposedITAT Delhi20 March 2026AY 2016-1715 pages
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What did the Tribunal hold?

The Tribunal held that the approval granted under Section 153D was vitiated due to non-application of mind, as evidenced by the identical wording of the proposal and approval across assessment years and entities. This mechanical approval fails to meet the statutory requirement of independent verification.

What were the facts?

The assessee appealed against assessment orders for multiple assessment years, arguing that the approval granted under Section 153D of the Income Tax Act was invalid due to a lack of independent application of mind by the approving authority. The approvals were identical across years and entities, suggesting a mechanical process.

What were the issues?

Whether the approval granted under Section 153D of the Income Tax Act was valid when it was mechanically issued without independent application of mind by the approving authority.

Which sections of the Income-tax Act were involved?

Section 153D,Section 153C,Section 153A

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Cases cited in this judgment(5)Show list

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

Before: SHRIS.RIFAUR RAHMAN & SHRI SUDHIR KUMAR

For Appellant: Shri Sumit Lalchandani, Adv
For Respondent: Ms. Pooja Swaroop, CIT(DR)
Hearing: 26.02.2026

Heard together (6 matters)

ITA No. 4919/Del/2025
ITA No. 4920/Del/2025
ITA No. 4921/Del/2025
ITA No. 4922/Del/2025
ITA No. 4923/Del/2025
ITA No. 4924/Del/2025

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

PER S.RIFAUR RAHMAN, AM:

1.

These six appeals are filed by the assessee against the respective orders of ld. Commissioner of Income-tax Appeals-25, New Delhi [hereinafter referred to as ‘ld. CIT (A)] for Assessment Years 2015-16 to 2020-21 respectively. Since the issues involved in these appeals are inter-connected, hence, the appeals were heard together and disposed of by this common order for the sake of convenience, by dealing with the facts of assessment year 2015-16, being the lead

The order continues below.

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