9911796707
TMI Blog2024 (9) TMI 1671X X X X Extracts X X X X X X X X Extracts X X X X ..... ORDER PER MADHUMITA ROY, JM: The instant appeal filed by the assessee is directed against the order dated 12.07.2018 passed by the CIT(A)-IV, Kanpur, under Section 153A r.w.s 143(3) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') arising out of the Assessment Order dated 30.12.2017 passed by the Ld. DCIT, Central Circle, Noidafor Assessment Year 2014-15. 2. The appeal is bar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as also been reiterated before us by the Ld. Counsel appearing for the assessee which seems to be true and sufficient to grant relief in condoning the delay in preferring the appeal filed by the assessee before us. Hence, the delay is condoned. 3. The assessee before us has challenged the impugned order on few grounds including the additional grounds challenging the validity of the approval taken ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the assessee. Notice under Section 153A of the Act was issued and the issue was finalized upon making addition which was further confirmed by the First Appellate Authority and thus impugned before us. 5. At the time of hearing of the instant appeal, the Ld. Counsel appearing for the assessee submitted before us that the approval was done along with 110 in a single day on 29.12.2017 and it was c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vant observation made by the Hon'ble Delhi High Court is as follows: "17. Notably, the order of approval dated 20.12.2020 which was produced before us by the Learned Counsel for the assessee clearly signifies that a single approval has been granted for AYs. 2011-12 to 2017-18 in the case of the assessee. The said order also fails to make any mention of the fact that the draft assessment orders w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hority and no separate application of mind in the instant case in hand while granting approval altogether 110 assessment orders in a single day the same is nothing but the product of total non-application of mind and therefore, relying on the ratio laid down by the Hon'ble Delhi High Court, we do not hesitate to find the same arbitrary, erroneous and thus, liable to be treated as non-est in the ey ..... X X X X Extracts X X X X X X X X Extracts X X X X
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