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2023 (6) TMI 1328

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..... orted reason that there was no application of mind in granting them - HELD THAT:- As contention raised by revenue in seeking admission of the appeal is covered by Serajuddin and Co. Kolkata [ 2023 (3) TMI 785 - ORISSA HIGH COURT] as held even the bare minimum requirement of the approving authority having to indicate what the thought process involved was is missing in the aforementioned approval .....

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..... , JJ. For the Appellant : Radheyshyam Chimanka, Senior Standing Counsel and Avinash Kedia, Junior Standing Counsel. For the Respondents : Chitrasen Parida, Advocate. JUDGMENT 1. Mr. Chimanka, learned advocate, Senior Standing Counsel appears on behalf of revenue and submits, his client wants admission of appeal against order dated 29th November, 2019 passed by the Income Tax App .....

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..... Court in ACIT, Circle-1(2), Bhubaneswar vs. M/s. Serajuddin and Co. Kolkata in I.T.A. nos.39 to 45 of 2022 is not applicable to the facts and circumstances of the cases. 2. Mr. Parida, learned advocate appears on behalf of the assessee and submits, purported contention raised by revenue in seeking admission of the appeal is covered by Serajuddin and Co. Kolkata (supra). He relies on paragraphs .....

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..... t it meets the requirement of the law. As explained in the above cases, the mere repeating of the words of the statute, or mere rubber stamping of the letter seeking sanction by using similar words like 'see' or 'approved' will not satisfy the requirement of the law. This is where the Technical Manual of Office Procedure becomes important. Although, it was in the context of S .....

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