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Assessment u/s 153A in violation of section 153D - Simply because approval has been taken on the same date does not lead to any presumption that is mechanical or without application of mind by the approving authority. We agree with the contention of the ld. DR that, what is required in the statute is the approval of JCIT which was available on record and the detail have been mentioned in the assessment order also and there is no statutory requirement under the law that copy of such approval or opportunity of hearing is to be given to the assessee. - AT
Assessment u/s 153A in violation of section 153D - Simply because approval has been taken on the same date does not lead to any presumption that is mechanical or without application of mind by the approving authority. We agree with the contention of the ld. DR that, what is required in the statute is the approval of JCIT which was available on record and the detail have been mentioned in the assessment order also and there is no statutory requirement under the law that copy of such approval or opportunity of hearing is to be given to the assessee. - AT
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