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

ITA 4921/DEL/2025Status: DisposedITAT Delhi20 March 2026AY 2017-1815 pages
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What did the Tribunal hold?

The Tribunal held that the approval granted under Section 153D was invalid as it was mechanical, lacking application of mind, and not specific to each assessment year. The approving authority failed to demonstrate perusal of seized documents or independent consideration of the case.

What were the facts?

The assessee's appeals concerned the validity of assessment orders passed under Section 153C of the Income Tax Act. The primary contention was that the approval granted under Section 153D was mechanical and lacked independent application of mind by the approving authority.

What were the issues?

Whether the approval granted under Section 153D for assessment orders under Section 153C was valid, or if it was vitiated due to non-application of mind and mechanical issuance.

Which sections of the Income-tax Act were involved?

Section 153D,Section 153C

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Cases cited in this judgment(3)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

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 case. 2.

The order continues below.

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