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In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed
Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)
1) and Section 153D leave no room for doubt that approval with respect to "each assessment year" is to be obtained by the Assessing Officer on the draft assessment order before passing the assessment orders under Section 153A. 20. We further find that Hon’ble Delhi High Court in the case of PCIT vs. Shiv Kumar Nayyar (supra