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ITAT invalidated assessments due to improper approval under Section 153D. The Additional CIT failed to exercise proper supervisory authority by issuing a symbolic combined approval memo without considering factual positions, legal aspects, or incriminating search materials for individual assessment years. The approval was deemed a mere formality, lacking substantive review of assessment orders. CIT(A)'s dismissal of objections on grounds that approval powers were administrative was rejected as legally untenable. The Tribunal held that such perfunctory approval violated statutory requirements, rendering the assessments legally unsustainable. The matter was resolved in the assessee's favor, with the assessment orders being nullified due to procedural impropriety.
ITAT invalidated assessments due to improper approval under Section 153D. The Additional CIT failed to exercise proper supervisory authority by issuing a symbolic combined approval memo without considering factual positions, legal aspects, or incriminating search materials for individual assessment years. The approval was deemed a mere formality, lacking substantive review of assessment orders. CIT(A)'s dismissal of objections on grounds that approval powers were administrative was rejected as legally untenable. The Tribunal held that such perfunctory approval violated statutory requirements, rendering the assessments legally unsustainable. The matter was resolved in the assessee's favor, with the assessment orders being nullified due to procedural impropriety.
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