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Assessment u/s 153A - action of the JCIT u/s 153D is to be regarded as perfunctory and mechanical in subversion of the spirit of Section 153D. Such symbolic approval is unfounded in law. As a corollary, in the absence of any valid approval u/s 153D, the respective assessment orders giving cause of action in the form of captioned appeals requires to be quashed on this score also.
Assessment u/s 153A - action of the JCIT u/s 153D is to be regarded as perfunctory and mechanical in subversion of the spirit of Section 153D. Such symbolic approval is unfounded in law. As a corollary, in the absence of any valid approval u/s 153D, the respective assessment orders giving cause of action in the form of captioned appeals requires to be quashed on this score also.
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