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The ITAT held that the consolidated approval under section 153D for multiple assessment years was mechanical and lacked application of mind, rendering it invalid. Consequently, all consequential proceedings, including assessments framed based on such approval, were declared null and void. The tribunal relied on authoritative precedent emphasizing that a separate satisfaction note under section 153C must be recorded for each assessment year, and a consolidated approval for multiple years vitiates the entire assessment process. Accordingly, the appeal of the assessee was allowed, quashing the assessments framed pursuant to the impugned approval.
The ITAT held that the consolidated approval under section 153D for multiple assessment years was mechanical and lacked application of mind, rendering it invalid. Consequently, all consequential proceedings, including assessments framed based on such approval, were declared null and void. The tribunal relied on authoritative precedent emphasizing that a separate satisfaction note under section 153C must be recorded for each assessment year, and a consolidated approval for multiple years vitiates the entire assessment process. Accordingly, the appeal of the assessee was allowed, quashing the assessments framed pursuant to the impugned approval.
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