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TMI Blog2023 (6) TMI 1328X X X X Extracts X X X X X X X X Extracts X X X X ..... purported reason that there was no application of mind in granting them - HELD THAT:- As contention raised by revenue in seeking admission of the appeal is covered by Serajuddin and Co. Kolkata [ 2023 (3) TMI 785 - ORISSA HIGH COURT] as held even the bare minimum requirement of the approving authority having to indicate what the thought process involved was is missing in the aforementioned approv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dheyshyam Chimanka, Senior Standing Counsel and Avinash Kedia, Junior Standing Counsel. For the Respondents : Chitrasen Parida, Advocate. JUDGMENT 1. Mr. Chimanka, learned advocate, Senior Standing Counsel appears on behalf of revenue and submits, his client wants admission of appeal against order dated 29th November, 2019 passed by the Income Tax Appellate Tribunal (ITAT), Cuttack Bench, in IT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... M/s. Serajuddin and Co. Kolkata in I.T.A. nos.39 to 45 of 2022 is not applicable to the facts and circumstances of the cases. 2. Mr. Parida, learned advocate appears on behalf of the assessee and submits, purported contention raised by revenue in seeking admission of the appeal is covered by Serajuddin and Co. Kolkata (supra). He relies on paragraphs 22 to 25 to submit, there was no application ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in the above cases, the mere repeating of the words of the statute, or mere "rubber stamping" of the letter seeking sanction by using similar words like 'see' or 'approved' will not satisfy the requirement of the law. This is where the Technical Manual of Office Procedure becomes important. Although, it was in the context of Section 158BG of the Act, it would equally ap ..... X X X X Extracts X X X X X X X X Extracts X X X X
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