ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25, NEW DELHI, DELHI vs. HONEY ARORA, DELHI

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ITA 1012/DEL/2025Status: DisposedITAT Delhi09 January 2026AY 2017-18Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)1 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal, relying on various landmark precedents, held that the approval under Section 153D of the Income Tax Act, 1961, must be accorded separately for each assessment year, even when dealing with a single assessee. Therefore, the combined approval for all ten years was deemed invalid.

What were the facts?

The appeals and cross-objections involved a batch of ten cases pertaining to the assessee, Sh. Honey Arora, for assessment years 2010-11 to 2019-20. The core issue was the validity of the assessments, which had received a combined approval for all ten years. The assessee's primary argument was that the approval under Section 153D of the IT Act should have been granted separately for each assessment year.

What were the issues?

Whether the combined approval granted by the prescribed authority for multiple assessment years for the purpose of proceedings under Section 153A of the Income Tax Act, 1961, is valid.

Which sections of the Income-tax Act were involved?

Section 153D,Section 153A

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(2)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: ‘E’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA

Hearing: 05.01.2026Pronounced: 09.01.2026

Heard together (10 matters)

ITA No.889/Del/2025
C.O. No.259/Del/2025
ITA No.998/Del/2025
C.O. No.260/Del/2025
ITA No.1012/Del/2025
C.O. No.261/Del/2025
ITA No.1014/Del/2025
C.O. No.262/Del/2025
ITA No.1015/Del/2025
C.O. No.263/Del/2025

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

ORDER PER BENCH: The instant batch of ten cases pertains to the single assessee herein, namely, Sh. Honey Arora. All other relevant details thereof are tabulated as under:

1.

ITA Nos.889, 998, 1012, 1014 & 1015/Del/2025 C.O. Nos.259 to 263/Del/2025 Sl. Appeal No. Appellant Respondent Order Appealed against No. 1- Central Honey Arora, CIT(A), Delhi’s-31’s order 889/Del/2025 Circle-25, Delhi dated 13.11.2024 having WITH New Delhi DIN & Order No. C.O. No. ITBA/APL/S/250/2024- 259/Del/2025 25/1070340573(1) involving for AY: 2010-11 proceedings under Section 153A of the Act. 3- ACIT, Central Honey Arora, CIT(A), Delhi-31’s order /Del/2025 Circle-25, Delhi dated 13.11.2024 having WITH New Delhi DIN & Order No. C.O. No. ITBA/APL/S/250/2024- 260/Del/2025 25/1070340951(1) involving for AY: 2016-17 proceedings under Section 153A of the Act. 5- ACIT, Central Honey Arora, CIT(A), Delhi-31’s order /Del/2025 Circle-25, Delhi dated 13.11.2024 having WITH New Delhi DIN & Order No. C.O. No. ITBA/APL/S/250/2024- 261/Del/2025 25/1070340726(1) involving for AY: 2017-18 proceedings under Section 153A of the Act. 7- ACIT, Central Honey Arora, CIT(A), Delhi-31’s order /Del/2025 Circle-25, Delhi dated 13.11.2024 having WITH New Delhi DIN & Order No. C.O. No. ITBA/APL/S/250/2024- 262/Del/2025 25/1070340684(1) involving for AY: 2018-19 proceedings under Section 153A of the Act. 9- ACIT, Central Honey Arora, CIT(A), Delhi-31’s order /Del/2025 Circle-25, Delhi dated 13.11.2024 having WITH New Delhi DIN & Order No. C.O. No. ITBA/APL/S/250/2024- 263/Del/2025 25/1070340626(1) involving for AY: 2019-20 proceedings under Section 153A of the Act.

Heard both the parties at length. Case files perused.

2.

It emerges during the course of hearing that there arises the first and foremost issue of validity of the impugned assessments itself as the learned prescribed authority herein had accorded its combined approval dated 23rd April, 2021 (page 557 of the paper- book) for ten assessment years 2010-11 to 2019-20 in the 2 | P a g e , 998, 1012, 1014 & 1015/Del/2025 C.O. Nos.259 to 263/Del/2025 assessee’s case. Various recent landmark precedents i.e. PCIT Vs. Shiv Kumar Nayyar (2024) 467 ITR 186 (Del.), PCIT Vs. Anuj Bansal (2024) 466 ITR 254 (SC) and PCIT Vs. MDLR Hotels (P.) Ltd. (2024) 166 taxmann.com 327 (Del.) have already settled the issue in assessee’s favour and against the department that such an approval under section 153D has to be accorded separately for each and every assessment year even if it involves a single assessee. We thus accept the assessee’s instant first and foremost legal ground/argument to quash the impugned assessment herein framed by the learned Assessing Officer on 24.04.2021 in very terms.

All other pleadings between the parties on merits are hereby rendered academic.

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