Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
ITAT held that the approval accorded under s.153D was a mechanical, omnibus sanction lacking any application of mind and therefore vitiated the resultant assessment orders. A single approval memo purportedly covering multiple assessment years and distinct assessees (totaling twenty-one approvals) without reference to materials reviewed or independent reasoning by the approving authority failed to satisfy statutory requisites; such rubber-stamping cannot sustain the assessments. Consequentially, the appeals by the assessees were allowed and the impugned assessment orders set aside/quashed insofar as they rested on the defective s.153D approval.
ITAT held that the approval accorded under s.153D was a mechanical, omnibus sanction lacking any application of mind and therefore vitiated the resultant assessment orders. A single approval memo purportedly covering multiple assessment years and distinct assessees (totaling twenty-one approvals) without reference to materials reviewed or independent reasoning by the approving authority failed to satisfy statutory requisites; such rubber-stamping cannot sustain the assessments. Consequentially, the appeals by the assessees were allowed and the impugned assessment orders set aside/quashed insofar as they rested on the defective s.153D approval.
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