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 372,010 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.

Raghav Bahl, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 742/DEL/2023[2016-17]Status: DisposedITAT Delhi07 Nov 2025AY 2016-17

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

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

…erned 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.” 20. 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 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 Section 153D of…

Raghav Bahl, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 741/DEL/2023[2015-16]Status: DisposedITAT Delhi07 Nov 2025AY 2015-16

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

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

…erned 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.” 20. 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 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 Section 153D of…

Raghav Bahl, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 740/DEL/2023[2014-15]Status: DisposedITAT Delhi07 Nov 2025AY 2014-15

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

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

…erned 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.” 20. 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 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 Section 153D of…

Raghav Bahl, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, Appeals filed by the Assessee in ITA

ITA 739/DEL/2023[2013-14]Status: DisposedITAT Delhi07 Nov 2025AY 2013-14

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

Section 120Section 143(2)Section 143(3)Section 153ASection 153BSection 153D

…erned 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.” 20. 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 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 Section 153D of…

Ramji Vaish, Allahabad vs. DCIT(CC), 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 38/ALLD/2023[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

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…

Ramji Vaish, Allahabad vs. DCIT, (CC), 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 37/ALLD/2023[2006-07]Status: DisposedITAT Allahabad31 Oct 2025AY 2006-07

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…

Ramji Vaish, Allahabad vs. DCIT, (CC), 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 36/ALLD/2023[2005-06]Status: DisposedITAT Allahabad31 Oct 2025AY 2005-06

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…

Ramji Vaish, Allahabad vs. DCIT(CC), 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 127/ALLD/2023[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

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…

Ramji Vaish, Allahabad vs. DCIT(CC), 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 126/ALLD/2023[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

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…

Ramji Vaish, Allahabad vs. DCIT(CC), 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 125/ALLD/2023[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

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…

Ramji Vaish, Allahabad vs. DCIT(C.C.), 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 101/ALLD/2023[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…

Asstt. Commissioner of Income Tax, Central Circle, Allahabad vs. Vijay Stone Product, Sonebhadra

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 65/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

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…

Asstt. Commissioner of Income Tax Central Circle, Allahabad vs. Vijay Stone Products, Sonebhadra

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 64/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

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…

Vijay Stone Product, 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 33/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

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…

Vijay Stone Product, 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 32/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

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…

Vijay Stone Product, 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 31/ALLD/2019[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

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…

Vijay Stone Product, 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 30/ALLD/2019[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

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…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, 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 25/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

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…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, 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 24/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

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…

M/S Subhash Stone Product Private Limited, 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 108/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

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…