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ITAT adjudicated a tax assessment case involving section 153A and 153D approval process. The tribunal critically examined the approval mechanism, emphasizing that administrative sanction must not be a mere formality but require substantive reasoning and genuine examination of record. The court found the specific approval lacking in judicial application of mind, demonstrating procedural deficiency. Critically, the approval was deemed mechanically granted without proper evaluation of underlying documentary evidence. Consequently, the tribunal declared the approval invalid, rendering the entire assessment order void ab initio. The assessee's appeal was allowed, effectively nullifying the proposed tax assessment based on procedural impropriety in the approval process.
ITAT adjudicated a tax assessment case involving section 153A and 153D approval process. The tribunal critically examined the approval mechanism, emphasizing that administrative sanction must not be a mere formality but require substantive reasoning and genuine examination of record. The court found the specific approval lacking in judicial application of mind, demonstrating procedural deficiency. Critically, the approval was deemed mechanically granted without proper evaluation of underlying documentary evidence. Consequently, the tribunal declared the approval invalid, rendering the entire assessment order void ab initio. The assessee's appeal was allowed, effectively nullifying the proposed tax assessment based on procedural impropriety in the approval process.
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