PCIT v. Shivgori Builders (P.) Ltd. (2026) 308 Taxman 94 (Delhi)(HC) PCIT v. Believe Constructions (P.) Ltd. (2026) 308 Taxman 134 (Delhi)(HC)

S. 153D: Assessment-Search and seizure-Approval-Single approval-Without reference to seized material or assessment records, such approval was invalid. [S.153A, 260A]

 

Dismissing the appeal of the revenue, the Court held that where a competent authority, while granting approval for a draft assessment order, issued a single consolidated letter covering multiple proposed assessments, giving a generic direction to pass orders before limitation and to send copies for record, without reference to seized material or assessment records, such approval is not valid. Circular No. 3 of 2008, dt.  12-3-2008. (AY. 2006-07, 2007-08 & 2008-09)(AY. 2007-08)

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