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

ITA 4924/DEL/2025Status: DisposedITAT Delhi20 March 2026AY 2020-21Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR KUMAR (Judicial Member)15 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the approval granted under Section 153D was mechanical and lacked application of mind, as evidenced by the identical wording of proposals and approvals across years and entities. Consequently, the assessment orders were vitiated.

What were the facts?

The assessee's appeals concerned assessment orders passed under Section 153C of the Income Tax Act. The core issue was the validity of the approval granted under Section 153D for these orders.

What were the issues?

Whether the approval granted under Section 153D for passing assessment orders under Section 153C was valid, or if it was granted mechanically without due application of mind, thereby vitiating the assessment.

Which sections of the Income-tax Act were involved?

Section 153D,Section 153C

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(7)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 (3 matters)

ITA No. 4920/Del/2025
ITA No. 4922/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

2.

Assessee has raised as many as 17 grounds, but Ld. AR of the Assessee only argued the Ground 4

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 153D

All 2,907 judgments and leading authorities on Section 153D →

Recent GST High Court judgments

Search GST case law →