Section 153D of the Income Tax Act, 1961– Search and Seizure– Legal ground challenging the validity of procedure adopted by the revenue in granting approval under section 153D which is purely legal ground going to the root of the matter and can be decided on the basis of material already on record raised for the first time before Tribunal is admitted– Dilip Constrcirions P ltd v Assistant Commissioner of income tax[2020] 203 (Cuttack) 422