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The case involved a challenge to the validity of approval u/s 153D for assessment u/s 153A. The Appellate Tribunal found that the approval granted by the JCIT was mechanical without due application of mind. The approval covered multiple assessment years in a single day, contrary to the requirement of section 153D. Citing a similar case, it held that such approval without proper consideration is fatal to search assessment proceedings. The Tribunal concluded that the approval was granted in a mechanical manner, rendering it an empty ritual, and ruled in favor of the assessee.
The case involved a challenge to the validity of approval u/s 153D for assessment u/s 153A. The Appellate Tribunal found that the approval granted by the JCIT was mechanical without due application of mind. The approval covered multiple assessment years in a single day, contrary to the requirement of section 153D. Citing a similar case, it held that such approval without proper consideration is fatal to search assessment proceedings. The Tribunal concluded that the approval was granted in a mechanical manner, rendering it an empty ritual, and ruled in favor of the assessee.
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