2023 (6) TMI 1328

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..... nding 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 Appellate Tribunal (ITAT), Cuttack Bench, in IT(ss) A Nos. 66/CTK/2018 and IT(ss) A No. 134/CTK/2018 for the assessment .....

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..... plicable 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 22 to 25 to submit, there was no application of mind by the Joint Commissioner in granting the approval of 27 cases, o .....

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..... "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 Section 158BG of the Act, it would equally apply to Section 153D of the Act. There are three or four requirements that are mandated t .....

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