ORDER

PER SATBEER SINGH GODARA, JM

These assessee’s and Revenue’s cross appeals ITA Nos. 2566/Del/2022 and 2822/Del/2022 for assessment year 2018-19 are directed against the Commissioner of Income Tax (Appeals)-31, New Delhi’s order dated 12.09.2022 passed in case no 657/20-21, involving proceedings under section 143(3) r.w.s. 153A of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

2. Heard both the parties. Case files perused.

3. It emerges at the outset that the assessee herein canvassing his first and foremost legal ground seeking to annul the impugned section 153A r.w.s. 143(3) assessment framed on 31st December, 2019 for want of invalid approval under section 153D of the Act.

4. Faced with this situation, learned CIT(DR) has filed detailed written submission vehemently contesting the assessee’s legal arguments as under:

“Sub: Written Submission in the Appeal of Hari Kishan Rathi, having ITA Nos. 2566 & 2822/Del/2022, A.Y. 2018-19, on the legal ground of valid