SAURABH SANGAL C/O B K KAPUR & COMPANY,GHAZIABAD vs. DCIT, NOIDA, NOIDA

This assessee’s appeal for assessment year 2018-19, arises against the Commissioner of Income Tax (Appeals)-3 [in short, the “CIT(A)”], Noida’s order dated 23.07.2025 in case no. CIT(A),
Kanpur-4/10953/2019-20 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.
2. It emerges at the outset that the assessee herein canvasses his first and foremost legal ground seeking to annul the impugned
Assessee by Sh. Madhav Kapur, Adv.
Department by Sh. Manoj Kumar, Sr. DR
Date of hearing
29.10.2025
Date of pronouncement
29.10.2025
2 | P a g e section 143(3) assessment framed on 29.12.2019 for want of a valid approval under section 153D of the Act.
3. I have given our thoughtful consideration to the assessee’s and the Revenue’s respective vehement contentions regarding the first and foremost issue of validity of the impugned assessment as lacking valid approval under section 153D of the Act. The assessee has filed the learned prescribed authority’s common approval granted in eleven different cases, dated 28.12.2019 which has already been declared as non-est in the eyes of law in ITA No.
2310/Del/2025, dated 16.06.2025 (Tish Consultants Pvt. Ltd. Vs.
ITR 186 (Del.) have further settled the issue in assessee’s favour and against the department that such combined approval under section 153D has to be accorded separately for each and every assessment year even if it involves a single assessee. I thus accept the assessee’s instant first and foremost legal ground/argument to 3 | P a g e quash the impugned assessment herein framed by the Assessing
Officer on 29th December, 2019 in very terms.

All other pleadings on merits herein stand rendered academic.
4. This assessee’s appeal is allowed.
Order pronounced in the open court on 29th October, 2025 (SATBEER SINGH GODARA)

JUDICIAL MEMBER

Dated: 29th October, 2025. RK/-