What is ACIT v. Serajuddin & Co. authority for?

Approval under Section 153D of the Income Tax Act is mandatory for assessment orders in search cases. While elaborate reasons for approval are not required, the approving authority must provide some indication that it has examined the draft orders and found them to meet the requirements of law.

How many judgments cite ACIT v. Serajuddin & Co.?

580 judgments on BharatTax cite ACIT v. Serajuddin & Co. (454 ITR 312), spanning 2023 to 2026.

Which sections of the Income Tax Act does ACIT v. Serajuddin & Co. come up under?

It is most often cited in judgments turning on Section 153D, Section 153A, Section 143(3), Section 132, Section 153C, Section 115BBE.

ACIT v. Serajuddin & Co. (454 ITR 312)

Subhash Stone Product (P) Ltd., Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 107/ALLD/2019[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh

Section 132(1)Section 153Section 153ASection 153DSection 250

…rds before the submission of the draft assessment orders and therefore, had too little time to apply his independent mind to the facts of the case. 34. The next important decision which has been cited before us the decision of ACIT vs. Serajuddin & Co. (2023) 454 ITR 312 (Orissa). In this case, the Hon’ble High Court had observed that the requirement of prior approval under section 153D of the Act was comparable with a similar requirement under section 158BG of the Act and quoting from para 9 of Chapter 3 of Volume -II (Technical) of the manual of office procedure issued by the CBDT in February, 2003 in respect o…

The Wine Connection, Gurgaon vs. ACIT Central Circle-14, Delhi

In the result, the appeal of the Assessee in ITA No

ITA 3538/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Oct 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 3537/Del/2025 (A.Y. 2016-17) The Wine Connection Vs The Assistant Commissioner Shop No. 22 & 23, Dlf Cyber Of Income Tax, Hub, Gurugram, Haryana- Central Circle-14, 122001 New Delhi Pan: Aaift6798A Appellant Respondent Assessee By Sh. Yudhister Mehtani, Ca Revenue By Ms. Amisha S. Gupta, Cit(Dr) Date Of Hearing 07/10/2025 Date Of Pronouncement 28/10/2025 Order

Section 143(3)Section 153ASection 153CSection 153D

…oncerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vsSerajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval The Wine Connection Vs. ACIT…

The Wine Connection, Gurgaon vs. ACIT, Central Circle-14, New Delhi

In the result, the appeal of the Assessee in ITA No

ITA 3537/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Oct 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 3537/Del/2025 (A.Y. 2016-17) The Wine Connection Vs The Assistant Commissioner Shop No. 22 & 23, Dlf Cyber Of Income Tax, Hub, Gurugram, Haryana- Central Circle-14, 122001 New Delhi Pan: Aaift6798A Appellant Respondent Assessee By Sh. Yudhister Mehtani, Ca Revenue By Ms. Amisha S. Gupta, Cit(Dr) Date Of Hearing 07/10/2025 Date Of Pronouncement 28/10/2025 Order

Section 143(3)Section 153ASection 153CSection 153D

…oncerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vsSerajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval The Wine Connection Vs. ACIT…

The Wine Connection, Gurgaon vs. ACIT, Central Circle-14, Delhi

In the result, the appeal of the Assessee in ITA No

ITA 3536/DEL/2025[2015-16]Status: DisposedITAT Delhi28 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 3537/Del/2025 (A.Y. 2016-17) The Wine Connection Vs The Assistant Commissioner Shop No. 22 & 23, Dlf Cyber Of Income Tax, Hub, Gurugram, Haryana- Central Circle-14, 122001 New Delhi Pan: Aaift6798A Appellant Respondent Assessee By Sh. Yudhister Mehtani, Ca Revenue By Ms. Amisha S. Gupta, Cit(Dr) Date Of Hearing 07/10/2025 Date Of Pronouncement 28/10/2025 Order

Section 143(3)Section 153ASection 153CSection 153D

…oncerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vsSerajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval The Wine Connection Vs. ACIT…

ACIT, CC- 15, New Delhi vs. Saloni Narang, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1496/DEL/2018[2012-13]Status: DisposedITAT Delhi27 Oct 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2012-13] Asst. Commissioner Of Income Saloni Narang, Tax, Central Circle-15, 5, Dr. G.G. Narang Marg, Room No.353, E-2, Ara Vs Cavalary Lane, Centre, Jhandewalan Ext. Delhi-110007 New Delhi-110055 Pan-Aafpn2692C Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv. & Shri Somil Agarwal, Adv. Revenue By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 27.10.2025

Section 132Section 143(3)Section 153Section 153ASection 153DSection 69A

…ranting approval has to apply its mind for "each assessment year" for "each assessee" separately. 13. Reliance can also be placed upon the decision of the Orissa High Court in the case of Asst. CIT v. Serajuddin & Co. [2023] 150 taxmann.com 146/292 Taxman 566/454 ITR 312/SCC OnLine Ori 992 to understand the exposition of law on the issue at hand. Paragraph no.22 of the said decision reads as under: "22. As rightly pointed out by learned counsel for the assessee there is not even a token mention of the draft orders having been perused by the Additional Commissioner of Income-tax. The letter simply grants an approv…

Vineet Prakash Bansal HUF, Moh. Khatiyan, Dhampur vs. DCIT/ACIT(Central), Moradabad

In the result, the appeal of the Assessee in ITA No

ITA 3110/DEL/2025[2015-16]Status: DisposedITAT Delhi24 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Vineet Prakash Bansal Huf Vs Income Tax Officer, Moh. Khatiyan, Dhampur, Aayakar Bhawan, New Civil Bijnor, Uttar Pradesh Lines, Moradabad, Pan:Aadhv3779A Uttar Pradesh Appellant Respondent

Section 132Section 153CSection 153DSection 69

…oncerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vsSerajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval under s. 153D of the Act bein…

Kailash Gahlot, New Delhi vs. DCIT, Central Circle-4, New Delhi

In the result, the appeal of the assessee is partly allowed as above

ITA 3431/DEL/2023[2015-16]Status: DisposedITAT Delhi24 Oct 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.3431/Del./2023, A.Y. 2015-16 Kailash Gahlot Deputy Commissioner Of C-6/6172, Vasant Kunj, Income Tax, New Delhi Vs. Central Circle-4, Pan: Aajpg2849N New Delhi (Appellant) (Respondent) Appellant By Sh. Vinod Kumar Bindal, Ca Sh. Anmol Jha, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 24/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2015-16 Is Directed Against The Order Dated 30.09.2023 Of The Commissioner Of Income Tax (Appeals)-23, New Delhi [‘Cit(A)’].

Section 115BSection 132(4)Section 153DSection 69C

…oordinate benches quashing assessments on the mechanical approval of the assessment by the Range Head. He relied upon the decisions in case of Hon’ble Orissa High Court, in the case of Sirajuddin & Co. (2023) 150 taxman.com 146 (Orissa) and Anuj Bansal (2024) 466 ITR 251 (Delhi). 11. On the other hand, the Ld. CIT-DR defended orders of the Authorities below. The Ld. CIT-DR argued that the assessment based on seized material clearly demonstrated the application of mind not only by the Ld. AO but also by the Ld. Range Head, who approved the said assessment order under section 153D of the Act and that was why the u…

Vivaan Prakash, Bijnor vs. DCIT/ACIT(Central), Moradabad

In the result, the appeal of the Assessee in ITA No

ITA 1500/DEL/2023[2018-2019]Status: DisposedITAT Delhi24 Oct 2025AY 2018-2019

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Vivaan Prakash Vs Dcit/Acit (Central) S/O Vibhu Prakash Bansal, Aaykar Bhawan, Civil Lines, Khatiyaan Street, Dhampur, Moradabad, Bijnor, Uttar Pradesh Uttar Pradesh Pan:Dggpp9920P Appellant Respondent Assessee By Sh. Amit Goel, Ca & Sh. Pravanv Yadav, Adv Revenue By Sh. Dayainder Singh Sidhu, Cit Dr Date Of Hearing 18/09/2025 Date Of Pronouncement 24/10/2025

Section 132Section 153CSection 153D

…concerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vsSerajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval under s. 153D of the Act bei…

Brij Kishore Sabharwal, Delhi vs. ACIT Central Circle-16, Delhi

In the result, the appeals of the Assessee in ITA Nos

ITA 574/DEL/2022[2016-17]Status: DisposedITAT Delhi24 Oct 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 572/Del/2022 (A.Y. 2014-15) Ita No. 574/Del/2022 (A.Y. 2016-17) Brij Kishore Sabharwal Vs Assistant Commissioner Of Rra Tax India D-28, South Income Tax, Extension Part-1 Delhi Central Circle-16, Pan: Aaxps6830P Delhi Appellant Respondent Assessee By Dr.Rakesh Gupta, Adv, Sh. Somil Agarwal, Adv (Through Vc) & Sh. Deepesh Garg, Adv Revenue By Sh. Dayainder Singh Sidhu, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 24/10/2025

Section 132Section 153CSection 153D

…oncerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vs Serajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval under s. 153D of the Act bein…

Brij Kishore Sabharwal, Delhi vs. ACIT Central Circle -16, Delhi

In the result, the appeals of the Assessee in ITA Nos

ITA 573/DEL/2022[2015-16]Status: DisposedITAT Delhi24 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 572/Del/2022 (A.Y. 2014-15) Ita No. 574/Del/2022 (A.Y. 2016-17) Brij Kishore Sabharwal Vs Assistant Commissioner Of Rra Tax India D-28, South Income Tax, Extension Part-1 Delhi Central Circle-16, Pan: Aaxps6830P Delhi Appellant Respondent Assessee By Dr.Rakesh Gupta, Adv, Sh. Somil Agarwal, Adv (Through Vc) & Sh. Deepesh Garg, Adv Revenue By Sh. Dayainder Singh Sidhu, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 24/10/2025

Section 132Section 153CSection 153D

…oncerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vs Serajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval under s. 153D of the Act bein…

Brij Kishore Sabharwal, Delhi vs. ACIT Central Circle-16, Delhi

In the result, the appeals of the Assessee in ITA Nos

ITA 572/DEL/2022[2014-15]Status: DisposedITAT Delhi24 Oct 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 572/Del/2022 (A.Y. 2014-15) Ita No. 574/Del/2022 (A.Y. 2016-17) Brij Kishore Sabharwal Vs Assistant Commissioner Of Rra Tax India D-28, South Income Tax, Extension Part-1 Delhi Central Circle-16, Pan: Aaxps6830P Delhi Appellant Respondent Assessee By Dr.Rakesh Gupta, Adv, Sh. Somil Agarwal, Adv (Through Vc) & Sh. Deepesh Garg, Adv Revenue By Sh. Dayainder Singh Sidhu, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 24/10/2025

Section 132Section 153CSection 153D

…oncerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vs Serajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval under s. 153D of the Act bein…

Brij Kishore Sabharwal, Delhi vs. ACIT Central Circle-16, Delhi

In the result, the appeals of the Assessee in ITA Nos

ITA 571/DEL/2022[2013-14]Status: DisposedITAT Delhi24 Oct 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 572/Del/2022 (A.Y. 2014-15) Ita No. 574/Del/2022 (A.Y. 2016-17) Brij Kishore Sabharwal Vs Assistant Commissioner Of Rra Tax India D-28, South Income Tax, Extension Part-1 Delhi Central Circle-16, Pan: Aaxps6830P Delhi Appellant Respondent Assessee By Dr.Rakesh Gupta, Adv, Sh. Somil Agarwal, Adv (Through Vc) & Sh. Deepesh Garg, Adv Revenue By Sh. Dayainder Singh Sidhu, Cit Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 24/10/2025

Section 132Section 153CSection 153D

…oncerned authority has granted approval for 43 cases in a single day which is evident from the findings of the ITAT, succinctly encapsulated in the order extracted above.” 9. Significantly, the Hon’ble Orissa High Court in the case of ACIT vs Serajuddin& Co. 454 ITR 312 (Orissa) had an occasion to examine substantial question of law on the propriety of approval granted under Section 153D of the Act. The Orissa High Court made wide ranging observations towards the manner and legality of approval under s. 153D of the Act. The Hon’ble High Court inter-alia observed that the approval under s. 153D of the Act bein…