MAMTA SHARDA,MEERUT vs. ACIT, CENTRAL CIRCLE, MEERUT

The assessees, Mrs. Reema Sharda and Mrs. Mamta Sharda, have filed appeals against the order of the Learned Commissioner of Income-tax (Appeals)-3, Noida [“Ld. CIT(A)”, for short] dated 10.06.2025 and 24.12.2024 for the Assessment Years 2022-23 and 2021-22 respectively.

At the outset, ld. AR of the assessee submitted that the assessee has challenged the legal issue that the authority under section 148B of the Income-tax Act, 1961 erred in not granting appropriate approval as required u/s 148B of the Act. He submitted that the approval granted by the authority u/s 148B is mechanical and without application of mind and hence, the consequent assessment order is bad in law and needs to be quashed. Further he submitted that the approval dated 23.05.2023 granted by the authority u/s 148B of the Act is bad in law inasmuch as a single approval has been granted for six assessees including the assessees in the present impugned assessment order. He submitted that the coordinate Bench in a batch of eight cases involving three assessees, namely, Mr. Manish Sharda, Ms. Mamta And Ms. Rakhi Sharda, on the similar issue allowed the appeals by quashing the assessments vide order dated 30.04.2025 and filed a copy of the same in the record. Accordingly, he pleaded that the assessments in the present cases may also be quashed.

On the other hand, ld. DR of the Revenue relied on the orders of the authorities below but could not controvert the aforesaid proposition.

That being the case, I adopt the judicial consistency to quash all these assessments framed on 24.05.2023 and 09.06.2023 in all these assessee’s appeals pertaining to assessment years 2019-20, 2020-21 and 2021-22, respectively.

All other pleadings on merits stand rendered academic. to 266/Del/2025 4 | P a g e 6. These three assessees’ eight respective appeals are allowed in above terms. A copy of this common order be placed in the respective case files.”