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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI S RIFAUR RAHMAN, ACM, SHRI ANUBHAV SHARMA, JM
Zeal Impex & Traders Private Limited – Appellant
Versus
DCIT, CC-25 – Respondent
| Table of Content |
|---|
| 1. case involves appeal against the commissioner’s order. (Para 1 , 2) |
| 2. approval granted under section 153d is contested. (Para 3 , 4 , 5) |
| 3. court analyzes the adequacy of approval process. (Para 6 , 7) |
| 4. findings indicate approval was mechanical. (Para 8) |
ORDER
PER ANUBHAV SHARMA, JM:
This appeal is preferred by the assessee against the order dated 29.12.2023 of the Commissioner of Income-tax (Appeals)-28, New Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. ‘FAA’) in Appeals No: 29/10405/2013-14 arising out of the appeal before it against the order dated 09.03.2021 passed u/s 153C/143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the DCIT, Central Circle- 25, New Delhi (hereinafter referred to as the Ld. AO) for AY: 2014-15.
2. The assessee company had filed return on 24.09.2014 and subsequent to a search in the case of Surendra Kumar Arya, JBM group of companies and key officers of the group on 05.10.2017 allegedly certain documents and digital data indicating under invoicing and suppression of scrap sales by JBM group companies to various scrap dealers were found and seized. The assessee’s case was according
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