Smt. Shreelekha Damani v. Deputy Commissioner of Income-tax (OSD-1), CR-7, Mumbai

88 Taxmann.com 383Reported decision2017#1324 most cited

What is Smt. Shreelekha Damani v. Deputy Commissioner of Income-tax (OSD-1), CR-7, Mumbai authority for?

The application of mind by the approving authority is essential for the validity of approval granted under section 153D of the Income Tax Act. Failure to apply mind renders the approval invalid.

86

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2019 to 2026.

Also referred to as

Smt. Shreelekha Damani v. Deputy Commissioner of Income-tax · section 153D · approval · application of mind · validity of assessment order · natural justice

Sections most often in play

Section 143(3)Section 115BBESection 153ASection 143(2)Section 153DSection 139(1)Section 142(1)Section 158BG

Issues it is cited on

section 10(31a)section 100section 76section 142(2c)section 153b(1)(b)section 153b(1)rectification under section 154section 144basection 136section 43(3)section 193section 196

Judgments citing Smt. Shreelekha Damani v. Deputy Commissioner of Income-tax (OSD-1), CR-7, Mumbai

Bthina Kumara Swamy Reddy, Nellore vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee is allowed

ITA 289/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam18 Jun 2025AY 2019-20

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.287, 288 & 289/Viz/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy V. Dcit – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [Pan: Abxpb1094K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 40

…आयकर अपीलीय अधिकरण, धिशाखापटणम पीठ, धिशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM श्री िीरिल्ली दुर्ाा राि,न्याधयक सदस्य एिं श्री एस बालाकृष्णन, लेखा सदस्य के समक्ष BEFORE SHRI VEERAVALLI DURGA RAO, HON’BLE JUDICIAL MEMBER & SHRI S BALAKRISHNAN, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.Nos.287, 288 & 289/VIZ/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy v. DCIT – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [PAN: ABXPB1094K] (अपीलार्थी/ Ap…

Bathina Kumara Swamy Reddy, Nellore vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee is allowed

ITA 288/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam18 Jun 2025AY 2018-19

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.287, 288 & 289/Viz/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy V. Dcit – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [Pan: Abxpb1094K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 40

…आयकर अपीलीय अधिकरण, धिशाखापटणम पीठ, धिशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM श्री िीरिल्ली दुर्ाा राि,न्याधयक सदस्य एिं श्री एस बालाकृष्णन, लेखा सदस्य के समक्ष BEFORE SHRI VEERAVALLI DURGA RAO, HON’BLE JUDICIAL MEMBER & SHRI S BALAKRISHNAN, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.Nos.287, 288 & 289/VIZ/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy v. DCIT – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [PAN: ABXPB1094K] (अपीलार्थी/ Ap…

Bathina Kumara Swamy Reddy, Nellore vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the assessee is allowed

ITA 287/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam18 Jun 2025AY 2017-18

Bench: Shri Veeravalli Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.Nos.287, 288 & 289/Viz/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy V. Dcit – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [Pan: Abxpb1094K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153DSection 40

…आयकर अपीलीय अधिकरण, धिशाखापटणम पीठ, धिशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM श्री िीरिल्ली दुर्ाा राि,न्याधयक सदस्य एिं श्री एस बालाकृष्णन, लेखा सदस्य के समक्ष BEFORE SHRI VEERAVALLI DURGA RAO, HON’BLE JUDICIAL MEMBER & SHRI S BALAKRISHNAN, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.Nos.287, 288 & 289/VIZ/2025 (निर्धारणवर्ा/ Assessment Years: 2017-18, 2018-19 & 2019-20) Bathina Kumara Swamy Reddy v. DCIT – Central Circle -1 C.R. Building, Kannavari Thota Plot No. 7, Santhi Nagar Guntur – 522001, Andhra Pradesh Nellore - 524003 [PAN: ABXPB1094K] (अपीलार्थी/ Ap…

ACIT, New Delhi vs. M/S Subash Dabas, New Delhi

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

ITA 2399/DEL/2016[2009-10]Status: DisposedITAT Delhi25 Nov 2021AY 2009-10

Bench: Shri R.K. Panda & Ms. Suchitra Kamble[Assessment Year: 2009-10]

Section 132Section 133(6)Section 139(1)Section 153ASection 2(22)(e)Section 40Section 68Section 69

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘G’: NEW DELHI (Through Video Conferencing) BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS. SUCHITRA KAMBLE, JUDICIAL MEMBER [Assessment Year: 2009-10] The ACIT, Sh. Subash Dabas, Central Circle-18, Prop. Tirupati Construction Co. Room No.102, ARA Centre, E-2, Plot No.3, Dwarka City Centre, Jhandewalan Extn. Sector-10, Dwarka, New Delhi New Delhi-110017 PAN-AAGPD6947F Revenue Assessee CO No.222/DEL/2016 (Arising out of ITA No.2399/DEL/2016) [Assessment Year: 2009-10] Sh. Subash Dabas, The ACIT, Prop. Tirupati Construction Co. Central Circle-18, Plot No.3, Dwa…

Shri Madal Lal, Jalandhar vs. Deputy Commissioner of Income Tax, Central Circle-1, Jalandhar

In the result, all the appeals of the Assessee are allowed

ITA 112/ASR/2018[2007-08]Status: DisposedITAT Amritsar16 Aug 2021AY 2007-08

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 153B(1)Section 153D

…ITA Nos. 112 to 118/Asr/2018 1 In the Income-Tax Appellate Tribunal, Amritsar Bench, Amritsar Before : Shri Laliet Kumar, Judicial Member And Dr. Mitha Lal Meena, Accountant Member ITA Nos. 112 to 118/Asr/2018 Assessment Year’s 2007-08 & 2013-14 Sh. Madan Lal V.S. DCIT Central Circle - I H.No. 24, Model Town, Jhalandhar MogaRoad,Shahkot, Jhalandhar PAN:ABFPL4650B (Appellant) (Respondent) Appellant by Sh. Salil Kapoor, Adv. Sh. Nirmal Mahajan, C.A. & Respondent by Smt. Rajindra Kaur, DR. Date of Hearing 15.07.2021 16.08.2021 Date of Pronouncement ORDER Per Laliet Kumar, J.M. The present appeal was filed by…

Neeru Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1991/DEL/2019[2015-16]Status: DisposedITAT Delhi19 Jan 2021AY 2015-16

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Duggal & Sons Buildwell (P) Ltd., Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1828/DEL/2019[2016-17]Status: DisposedITAT Delhi19 Jan 2021AY 2016-17

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Duggal & Sons Buildwell (P) Ltd., Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1827/DEL/2019[2015-16]Status: DisposedITAT Delhi19 Jan 2021AY 2015-16

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Duggal & Sons Buildwell (P) Ltd., Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1826/DEL/2019[2012-13]Status: DisposedITAT Delhi19 Jan 2021AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Duggal & Sons Buildwell (P) Ltd., Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1825/DEL/2019[2011-12]Status: DisposedITAT Delhi19 Jan 2021AY 2011-12

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Duggal & Sons Buildwell (P) Ltd., Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1824/DEL/2019[2010-11]Status: DisposedITAT Delhi19 Jan 2021AY 2010-11

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Duggal Estates Pvt. Ltd., Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1823/DEL/2019[2012-13]Status: DisposedITAT Delhi19 Jan 2021AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Arun Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1822/DEL/2019[2013-14]Status: DisposedITAT Delhi19 Jan 2021AY 2013-14

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Arun Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1821/DEL/2019[2012-13]Status: DisposedITAT Delhi19 Jan 2021AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Arun Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1820/DEL/2019[2011-12]Status: DisposedITAT Delhi19 Jan 2021AY 2011-12

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Arun Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1819/DEL/2019[2010-11]Status: DisposedITAT Delhi19 Jan 2021AY 2010-11

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Sanjay Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1818/DEL/2019[2015-16]Status: DisposedITAT Delhi19 Jan 2021AY 2015-16

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Sanjay Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1817/DEL/2019[2014-15]Status: DisposedITAT Delhi19 Jan 2021AY 2014-15

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Sanjay Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1816/DEL/2019[2013-14]Status: DisposedITAT Delhi19 Jan 2021AY 2013-14

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…

Sanjay Duggal, Faridabad vs. ACIT, Central Circle- 4, New Delhi

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

ITA 1815/DEL/2019[2012-13]Status: DisposedITAT Delhi19 Jan 2021AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

…ead into the said provision. 200 ITA.No.1813/Del./2019 Shri Sanjay Duggal, Faridabad etc., & 51batch appeals Accordingly, we reiterate the view expressed in Rajesh Kumar's case (supra).” 4.13. Further, the coordinate bench in the matter of Shreelekha Damani 88 Taxmann.com 383 had held as under : “11.9. This decision of the Tribunal was considered by Allahabad Bench of the Tribunal in the case of Verma Roadways v. Asstt. CIT [2000] 75 ITD 183 wherein also the assessee-appellant has challenged the validity of approval to the assessment order accorded by the CIT Kanpur. The Tribunal at Para-47 has held as under :…