Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
The ITAT allowed the assessee's appeals, invalidating assessments under section 153A due to improper prior approval under section 153D. Following precedents from Orissa HC in ACIT v. Serajuddin & Co. and Delhi HC in PCIT v. Anuj Bansal, the Tribunal determined that the approval was granted mechanically without proper examination of assessment records or search materials. The approval merely contained a perfunctory statement without demonstrating application of mind by the Additional Commissioner. As the approval was procedurally defective and granted without substantive review, the resulting assessment orders were deemed legally vitiated and invalid.
The ITAT allowed the assessee's appeals, invalidating assessments under section 153A due to improper prior approval under section 153D. Following precedents from Orissa HC in ACIT v. Serajuddin & Co. and Delhi HC in PCIT v. Anuj Bansal, the Tribunal determined that the approval was granted mechanically without proper examination of assessment records or search materials. The approval merely contained a perfunctory statement without demonstrating application of mind by the Additional Commissioner. As the approval was procedurally defective and granted without substantive review, the resulting assessment orders were deemed legally vitiated and invalid.
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