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2023 (12) TMI 804 - ITAT DELHIValidity of notices issued u/s 153C - No valid approval as per mandate of sec 153D as alleged on absence of application of mind by the ACIT - addition u/s 68 - HELD THAT:- Since the copy of the letter of DCIT Central Circle Noida to JCIT Central Range Meerut and approval order issued by JCIT Meerut includes names of present assessee Smt. Ruchi Garg at serial no. 6 and M/s M.G Metalloy Pvt. Ltd. at serial no. 10, therefore, we have no hesitation to hold that the legal contention of assessee envisaged in ground of cross objection one is squarely covered in favour of the assessee leading to inevitable invalidation of assessment orders as the formal and cosmic approval accorded u/s. 153D of the Act issued without application of mind to the relevant assessment orders and records has to be rendered un-enforceable in law and hence the same is quashed. It is pertinent to mention that the said conclusion also gets strong support from the judgement of Anuj Bansal [2023 (7) TMI 1214 - DELHI HIGH COURT] as relied by the ld. AR. Our conclusion drawn for AY 2011-12 would also apply mutatis mutandis to other three appeals pertaining to AY 2012-13, 2013-14 & 2015-16 and consequently impugned reassessment orders in other three appeals are also quashed - Cross objection no. 1 is allowed
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