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        Case ID :
        Income Tax

        ITAT holds that approvals under s.153D were granted mechanically...

        Approvals under s.153D found mechanical and invalid; s.153A/s.153D assessments quashed; s.68 additions deleted where books rejected and s.144 best-judgment applied

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        Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

        Provisions expressly mentioned in the judgment/order text.

        ITAT holds that approvals under s.153D were granted mechanically and, being invalid, vitiate assessment orders framed under s.153A read with s.153D for AYs 2014-15 to 2019-20, which are quashed. Tribunal rules that additions under s.68 cannot be made for opening balances or notional book entries representing earlier years; such amounts and alleged unsecured loans shown as carried-forward balances are not exigible in the year under assessment and are deleted. Where books were rejected u/s 145(3) and best-judgment estimation u/s 144 was applied, no separate s.68 addition could be sustained. Alleged inter-unit profits cannot be recharacterized to avoid double taxation absent corroborative evidence.

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