Case of PCIT vs Ashutosh Developers Pvt Ltd, HC Delhi Judgement Dated 15th October 2025. The ITAT had found that the Additional CIT had accorded a blanket approval for 246 assessment orders by a single letter stating: “The above draft orders, as proposed, are hereby accorded approval with the direction to ensure that the orders are passed well before limitation period.” The Tribunal, relying on the legislative intent behind Section 153D and CBDT Circular held that such an approval defeats the object of ensuring supervisory application of mind by a higher authority in search-related assessments, thus invalid in law. The HC also dismissed the revenue appeal and held that approvals under Section 153D must be case-specific and demonstrate conscious satisfaction. Mass approvals covering dozens of assessments through one letter are invalid.