HONEY ARORA,DELHI V. ACIT, CIRCLE 25, DELHI

CO 259/DEL/2025

AI Insights

The case involves a series of appeals by the ACIT, Central Circle-25, New Delhi against Sh. Honey Arora concerning the assessment years 2010-11 to 2019-20. The core issue was the validity of the assessments made under Section 153A of the Income Tax Act, 1961, which were challenged due to the lack of separate approvals for each assessment year under Section 153D. The Tribunal referenced several landmark precedents which supported the assessee's position that each assessment year requires individual approval. Consequently, the Tribunal quashed the assessments and dismissed the appeals by the Revenue.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 827161 (ITAT-DELHI)
• Duration Of Justice: 1 month(s) 18 day(s)
• Appeal Type: Cross Objection
• Pronouncement Date: 09-01-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: E
• Assessment Year: 2010-2011
• Appeal Filed On: 21-11-2025
• Other Referred Cases: PCIT Vs. Shiv Kumar Nayyar (2024) 467 ITR 186 (Del.), PCIT Vs. Anuj Bansal (2024) 466 ITR 254 (SC), PCIT Vs. MDLR Hotels (P.) Ltd. (2024) 166 taxmann.com 327 (Del.)
• Laws Referred To: Section 153A of the Act, Section 153D of the Act
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: AMISH S. GUPT
• Assessee Lawyers: AMIT KUMAR GUPTA
• Section: 153A

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER ITA No.889/Del/2025 along with C.O. No.259/Del/2025 Assessment Year: 2010-11 With ITA No.998/Del/2025 along with C.O. No.260/Del/2025 Assessment Year: 2016-17 With ITA No.1012/Del/2025 along with C.O. No.261/Del/2025 Assessment Year: 2017-18 With ITA No.1014/Del/2025 along with C.O. No.262/Del/2025 Assessment Year: 2018-19 With ITA No.1015/Del/2025 along with C.O. No.263/Del/2025 Assessment Year: 2019-20 ACIT, Central Circle-25, New Delhi Vs. Sh. Honey Arora, A-101, 4th Floor, Sharda Puri, Ramesh Nagar, Delhi PAN: ARNPA8541J (Appellant) (Respondent/Cross-objector) ORDER PER BENCH: The instant batch of ten cases pertains to the single assessee herein, namely, Sh. Honey Arora. All other relevant details thereof are tabulated as under: Assessee by Sh. Amit Kumar Gupta, Adv. Department by Sh. Amish S. Gupt, CIT(DR) Date of hearing 05.01.2026 Date of pronouncement 09.01.2026 Printed from counselvise.com ITA Nos.889, 998, 1012, 1014 & 1015/Del/2025 C.O. Nos.259 to 263/Del/2025 2 | P a g e Sl. No. Appeal No. Appellant Respondent Order Appealed against 1-2 ITA No. 889/Del/2025 WITH C.O. No. 259/Del/2025 for AY: 2010-11 ACIT, Central Circle-25, New Delhi Honey Arora, Delhi CIT(A), Delhi’s-31’s order dated 13.11.2024 having DIN & Order No. ITBA/APL/S/250/2024- 25/1070340573(1) involving proceedings under Section 153A of the Act. 3-4 ITA No.998 /Del/2025 WITH C.O. No. 260/Del/2025 for AY: 2016-17 ACIT, Central Circle-25, New Delhi Honey Arora, Delhi CIT(A), Delhi-31’s order dated 13.11.2024 having DIN & Order No. ITBA/APL/S/250/2024- 25/1070340951(1) involving proceedings under Section 153A of the Act. 5-6 ITA No.1012 /Del/2025 WITH C.O. No. 261/Del/2025 for AY: 2017-18 ACIT, Central Circle-25, New Delhi Honey Arora, Delhi CIT(A), Delhi-31’s order dated 13.11.2024 having DIN & Order No. ITBA/APL/S/250/2024- 25/1070340726(1) involving proceedings under Section 153A of the Act. 7-8 ITA No.1014 /Del/2025 WITH C.O. No. 262/Del/2025 for AY: 2018-19 ACIT, Central Circle-25, New Delhi Honey Arora, Delhi CIT(A), Delhi-31’s order dated 13.11.2024 having DIN & Order No. ITBA/APL/S/250/2024- 25/1070340684(1) involving proceedings under Section 153A of the Act. 9-10 ITA No.1015 /Del/2025 WITH C.O. No. 263/Del/2025 for AY: 2019-20 ACIT, Central Circle-25, New Delhi Honey Arora, Delhi CIT(A), Delhi-31’s order dated 13.11.2024 having DIN & Order No. ITBA/APL/S/250/2024- 25/1070340626(1) involving proceedings under Section 153A of the Act. Heard both the parties at length. Case files perused. 2. It emerges during the course of hearing that there arises the first and foremost issue of validity of the impugned assessments itself as the learned prescribed authority herein had accorded its combined approval dated 23rd April, 2021 (page 557 of the paper- book) for ten assessment years 2010-11 to 2019-20 in the Printed from counselvise.com ITA Nos.889, 998, 1012, 1014 & 1015/Del/2025 C.O. Nos.259 to 263/Del/2025 3 | P a g e assessee’s case. Various recent landmark precedents i.e. PCIT Vs. Shiv Kumar Nayyar (2024) 467 ITR 186 (Del.), PCIT Vs. Anuj Bansal (2024) 466 ITR 254 (SC) and PCIT Vs. MDLR Hotels (P.) Ltd. (2024) 166 taxmann.com 327 (Del.) have already settled the issue in assessee’s favour and against the department that such an approval under section 153D has to be accorded separately for each and every assessment year even if it involves a single assessee. We thus accept the assessee’s instant first and foremost legal ground/argument to quash the impugned assessment herein framed by the learned Assessing Officer on 24.04.2021 in very terms. All other pleadings between the parties on merits are hereby rendered academic. 3. These Revenue’s five appeals ITA Nos.889, 998, 1012, 1014 & 1015/Del/2025 are dismissed and assessee’s cross objections C.O. Nos.259 to 263/Del/2025 are allowed in above terms. A copy of this common order be placed in the respective case files. Order pronounced in the open court on 9th January, 2026 Sd/- Sd/- (AMITABH SHUKLA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 9th January, 2026. Printed from counselvise.com ITA Nos.889, 998, 1012, 1014 & 1015/Del/2025 C.O. Nos.259 to 263/Del/2025 4 | P a g e RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi Printed from counselvise.com "