ACIT, CENTRAL CIRCLE-19, DELHI, DELHI vs. YASMIN KAPOOR, DELHI

ITA 3379/DEL/2025Status: DisposedITAT Delhi30 January 2026AY 2016-1732 pages
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What did the Tribunal hold?

The Tribunal held that the approval granted under Section 153D was mechanical and vitiated the assessment proceedings. This was because the approval was granted for multiple assessment years and multiple assessees in a single document without proper application of mind to each case.

What were the facts?

The appeals involved assessments made under Section 153A following a search. A key issue was whether the mandatory approval under Section 153D was granted mechanically without due application of mind.

What were the issues?

Whether the approval granted under Section 153D for search assessments was mechanical and lacked due application of mind, thereby invalidating the assessment.

Which sections of the Income-tax Act were involved?

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

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Cases cited in this judgment(12)Show list

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Heard together (5 matters)

ITA No. 2203/Del/2025
CO 97/Del/2025
ITA No. 3379/Del/2025
Co No. 98/Del/2025
ITA No. 2221/Del/2025

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INCOME TAX APPELLATE TRIBUNAL DELHI BENCH "A": NEW DELHI 6/14, Shanti Niketan, New Delhi (Respondent) PAN: AAUPT4464F

ACIT, Central Circle-19, Delhi (Appellant)

CO 97/Del/2025 (In ITA No. 2203/Del/2025) (Assessment Year: 2017-18) Deepa Talwar, 6/14, Shanti Niketan, New Delhi (Appellant) PAN: AAUPT4464F Vs. ACIT, Central Circle-19, Delhi (Respondent)

ITA Nos. 2203 & 2221/Del/2025 (Assessment Years: 2016-17 & 2017-18) Vs. Yasmin Kapoor, C-4/6, APJ Abdul Kalam ACIT, Central Circle-19, Delhi (Appellant) Road, New Delhi (Respondent) PAN: AGJPK1064B Vs. Yasmin Kapoor, C-4/6, APJ Abdul Kalam Road, New Delhi (Appellant) DCIT, Central Circle-19, Delhi (Respondent) PAN: AGJPK1064B

Co No. 98/Del/2025 (In ITA No. 2221/Del/2025 (Assessment Year: 2017-18) Yasmin Kapoor, C-4/6, APJ Abdul Kalam Road, New Delhi (Appellant) PAN: AGJPK1064B Vs. DCIT, Central Circle-19, Delhi (Respondent)

Assessee by : Shri Sanjay Kumar Agarwal, CA Shri Lakshay Gupta, CA Shri Sumaksh Mahajan, CA Reve

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