Navin Jain v. DCIT

91 ITR (Trib) 682Income Tax Appellate Tribunal2021#4974 most cited

What is Navin Jain v. DCIT authority for?

Approvals for assessment orders must be granted with independent application of mind by the approving authority, not mechanically, to be valid. Each assessment under section 153D for each assessee and each assessment year must be approved separately.

24

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2025 to 2025.

Also referred to as

Navin Jain v. DCIT · ITAT 2021 · section 153D · approval of draft assessment order · mechanical approval · application of independent mind · separate approval for each assessee and assessment year · vitiated assessment order

Sections most often in play

Section 153ASection 153DSection 143(3)Section 144ASection 148Section 40A(3)Section 234ASection 234B

Issues it is cited on

section 274(2)section 153(a)section 135asection 148bcasus omissusviolation of natural justicesection 271aaasection 132(4a)section 144asection 40a(3)section 158bcsection 142a

Judgments citing Navin Jain v. DCIT

ACIT, CENTRAL CIRCLE-II, LUCKNOW, LUCKNOW vs. RAKESH KUMAR PANDEY, GONDA U.P.

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 460/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…ts necessary for granting a considered approval in one day, the orders in question were passed after mechanical approval and therefore vitiated. The Hon’ble High Court after referring to the decisions of the Tribunal in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow) held that the approval of the draft assessment order being an inbuilt protection against any arbitrary or unjust power of the ld. AO cannot be a mechanical exercise without application of independent mind by the approving authority on the material placed before him and the reasoning given in the assessment order. It rejected the s…

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 351/LKW/2025[2018-19]Status: DisposedITAT Lucknow11 Dec 2025AY 2018-19

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…ts necessary for granting a considered approval in one day, the orders in question were passed after mechanical approval and therefore vitiated. The Hon’ble High Court after referring to the decisions of the Tribunal in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow) held that the approval of the draft assessment order being an inbuilt protection against any arbitrary or unjust power of the ld. AO cannot be a mechanical exercise without application of independent mind by the approving authority on the material placed before him and the reasoning given in the assessment order. It rejected the s…

RAKESH KUMAR PANDEY,GONDA vs. DCIT/ACIT (CENTRAL)-2, LUCKNOW

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 349/LKW/2025[2016-17]Status: DisposedITAT Lucknow11 Dec 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

…ts necessary for granting a considered approval in one day, the orders in question were passed after mechanical approval and therefore vitiated. The Hon’ble High Court after referring to the decisions of the Tribunal in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow) held that the approval of the draft assessment order being an inbuilt protection against any arbitrary or unjust power of the ld. AO cannot be a mechanical exercise without application of independent mind by the approving authority on the material placed before him and the reasoning given in the assessment order. It rejected the s…

ASSISTANT COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JYOTI MEDISERVICES LTD., ALLAHABAD

ITA 129/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, Range, Lucknow is clearly not in accordance with the provisions of the Act and therefore, renders the assessment orders as defective or vitiated. 46. The questi…

JYOTI MEDISERVICES PRIVATE LIMITED, ,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, , ALLAHABAD

ITA 115/ALLD/2025[2013-14]Status: DisposedITAT Allahabad21 Nov 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, Range, Lucknow is clearly not in accordance with the provisions of the Act and therefore, renders the assessment orders as defective or vitiated. 46. The questi…

JYOTI MEDISERVICES PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, ALLAHABAD

ITA 114/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, Range, Lucknow is clearly not in accordance with the provisions of the Act and therefore, renders the assessment orders as defective or vitiated. 46. The questi…

JYOTI MEDISERVICES PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, ALLAHABAD, ALLAHABAD

ITA 113/ALLD/2025[2011-12]Status: DisposedITAT Allahabad21 Nov 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, Range, Lucknow is clearly not in accordance with the provisions of the Act and therefore, renders the assessment orders as defective or vitiated. 46. The questi…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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

…ime, it is quite clear that the approval has not been granted in respect of ‘each assessee’ separately in respect of ‘each assessment year’ and, as observed by the Hon’ble Allahabad High Court by quoting from the ITAT in the case of Navin Jain vs. DCIT (2021) 91 ITR (Trib) 682 (Lucknow), the provisions of the Act require that each assessment under section 153D in respect of each assessee be approved separately. Thus, the approval granted by the ld. JCIT, ITA Nos.24 & 25/ALLD/2019 M/s Jai Maa Sharda Service Station ITA Nos. 105,106,107,108/ALLD/2019 M/s Subhash Stone Product (P.) Ltd. ITA Nos. 30,31,32,33/ALLD/201…

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Navin Jain v. DCIT (91 ITR (Trib) 682) — Cited in 24 Judgments | BharatTax