ACIT v. Serajuddin & Co.

454 ITR 312High Court2023#105 most cited

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.

580

judgments rely on this decision, according to BharatTax’s citation analysis of 372,241 Indian tax judgments — from 2023 to 2026.

Also referred to as

ACIT v. Serajuddin & Co. · 454 ITR 312 · Section 153D · approval · mandatory approval · legality of approval · reasons for approval · examination of draft orders · search assessment · income tax

Sections most often in play

Section 153DSection 153ASection 143(3)Section 132Section 153CSection 115BBESection 119Section 142(1)
Read the full judgment

Issues it is cited on

section 158bgsection 114(e)section 37bsection 43(3)section 158bsection 153dsection 153a(1)section 158section 144basection 144asection 158bdincome tax settlement commission

Judgments citing ACIT v. Serajuddin & Co.

Krishan Kumar Makrania Pro. M/S Makrania Oil Mill, Bhiwani vs. DCIT Central Circle-I, Gurgaon

In the result, the captioned appeals of the Assessees are allowed

ITA 491/DEL/2024[2015-16]Status: DisposedITAT Delhi17 Oct 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 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 bein…

Krishan Kumar Makrania Pro. M/S Makrania Oil Mill, Bhiwani vs. DCIT Central Circle-I, Gurgaon

In the result, the captioned appeals of the Assessees are allowed

ITA 490/DEL/2024[2014-15]Status: DisposedITAT Delhi17 Oct 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 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 bein…

Krishan Kumar Makrania Pro. M/S Makrania Oil Mill, Bhiwani vs. DCIT Central Circle-I, Gurgaon

In the result, the captioned appeals of the Assessees are allowed

ITA 489/DEL/2024[2013-14]Status: DisposedITAT Delhi17 Oct 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 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 bein…

Krishan Kumar Makrania Pro M/S. Makrania Oil Mill, Bhiwani vs. DCIT Central Circle-I, Gurgaon

In the result, the captioned appeals of the Assessees are allowed

ITA 488/DEL/2024[2012-13]Status: DisposedITAT Delhi17 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 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 bein…

Sahil Kohli, New Delhi vs. DCIT Central Circle-16, New Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 453/DEL/2024[2019-20]Status: DisposedITAT Delhi17 Oct 2025AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153ASection 250

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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- ITA Nos.3283/Del/2023 & Others alia observed that the appro…

Sahil Kohil, Delhi vs. DCIT, Central Circle-16, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 452/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153ASection 250

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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- ITA Nos.3283/Del/2023 & Others alia observed that the appro…

Makrania Group Gum & Chemicals, Bhiwani vs. DCIT Central Circle - I, Gurgaon

In the result, the captioned appeals of the Assessees are allowed

ITA 1506/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 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 bein…

Makrania Group Gum & Chemicals, Bhiwani vs. DCIT Central Circle - I, Gurgaon

In the result, the captioned appeals of the Assessees are allowed

ITA 1505/DEL/2024[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 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 bein…

Govind Ram Makrania Prop. M/S Laxmi Oil & Ginning Factory, Bhiwani vs. DCIT Central Circle - I, Gurgaon

In the result, the captioned appeals of the Assessees are allowed

ITA 1504/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 143(3)Section 153ASection 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 bein…

Deputy Commissioner of Income Tax Central Circle - 16, Delhi vs. Sahil Kohli, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 3283/DEL/2023[2015-16]Status: DisposedITAT Delhi17 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153ASection 250

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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- ITA Nos.3283/Del/2023 & Others alia observed that the appro…

Deputy Commissioner of Income Tax, Central Circle-16, Delhi vs. Kohli Tents Private Limited, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2956/DEL/2023[2013-14]Status: DisposedITAT Delhi17 Oct 2025AY 2013-14

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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…

Deputy Commissioner of Income Tax, Central Circle-16, Delhi vs. Key Events, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2740/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153CSection 250Section 69A

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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…

Deputy Commissioner of Income Tax, Central Circle-16, Delhi vs. Key Events, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2700/DEL/2023[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153CSection 250Section 69A

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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…

Deputy Commissioiner of Income Tax, Delhi vs. Key Events, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2699/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153CSection 250Section 69A

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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…

Deputy Commissioner of Income Tax Central Circle-16 Delhi, Delhi vs. Kohli Tents Private Limited, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2597/DEL/2023[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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…

Deputy Commissioner of Income Tax Central Circle 16 Delhi, Delhi vs. Kohli Tents Private Limited, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2596/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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…

Deputy Commissioner of Income Tax Central Circle 16 Delhi, Delhi vs. Kohli Tents Private Limited, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2595/DEL/2023[2015-16]Status: DisposedITAT Delhi17 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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…

Deputy Commissioner of Income Tax Central Circle - 16, Delhi vs. Kohli Tents Private Limited, New Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 2594/DEL/2023[2014-15]Status: DisposedITAT Delhi17 Oct 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 139(1)Section 143(2)Section 153ASection 250

…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." 14. Similarly, 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 s. 153D of the Act. The Hon’ble 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…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Aman Feed Industries, Khanna

In the result, appeals of the assessee for A

ITA 457/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 145(3)Section 153ASection 153DSection 250Section 68

…ble Supreme Court in the case of Additional Commissioner of Income-tax v. Serajuddin and Co. [2024] 163 taxmann.com 118 (SC) 2. Judgement passed by Hon'ble High Court of Orrisa in the case of Additional Commissioner of Income-tax vs. Serajuddin and Co. [2023] 454 ITR 312 (Orrisa) 3. Judgement passed by Hon'ble Supreme Court in the case of Principal Commissioner of Income Tax v. Anuj Bansal [2024] 466 ITR 254 (SC) 4. Judgement passed by Hon'ble High Court of Delhi in the case of Principal Commissioner of Income Tax (Central)-2 v. Anuj Bansal [2024] 466 ITR 251 (Delhi) 5. Judgement passed by Hon'ble High Court of D…

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. M/S Afi Agro Pvt. Ltd., Khanna

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 373/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh16 Oct 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1256, 1257,1258/Chd/2024 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 Afi Agro Private Limited, The Dcit, A-1, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 179,180,373/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs Afi Agro Private Limited, Central Circle-1, A-1, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aaeca6479L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms. Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Ashwani Kumar, Shri Kulbhushan Goyal &For Respondent: Shri Manav Bansal, CIT DR
Section 132Section 139(1)Section 139(4)Section 143(2)Section 153ASection 153D

…ble Supreme Court in the case of Additional Commissioner of Income-tax v. Serajuddin and Co. [2024] 163 taxmann.com 118 (SC) 2. Judgement passed by Hon'ble High Court of Orrisa in the case of Additional Commissioner of Income-tax vs. Serajuddin and Co. [2023] 454 ITR 312 (Orrisa) 3. Judgement passed by Hon'ble Supreme Court in the case of Principal Commissioner of Income Tax v. Anuj Bansal [2024] 466 ITR 254 (SC) 4. Judgement passed by Hon'ble High Court of Delhi in the case of Principal Commissioner of Income Tax (Central)-2 v. Anuj Bansal [2024] 466 ITR 251 (Delhi) 5. Judgement passed by Hon'ble High Court of D…