Consultancy fees claimed as business expense-can tax disallowance rest on survey suspicion despite invoices, contracts and bank trail? Appeal dismisse...
Validity of assessments framed under s.153A turned on whether mandatory approval under s.153D was granted with due application of mind. Where a single, joint approval was accorded for seven assessment years and the record did not evidence any meaningful interaction or scrutiny by the approving authority of the draft orders, the approval was held to be mechanical, perfunctory, and merely ritualistic, failing the statutory safeguard under s.153D. Consequently, the assessments founded on such symbolic approval were vitiated and were quashed, and the appeal was allowed. - ITAT
Validity of assessments framed under s.153A turned on whether mandatory approval under s.153D was granted with due application of mind. Where a single, joint approval was accorded for seven assessment years and the record did not evidence any meaningful interaction or scrutiny by the approving authority of the draft orders, the approval was held to be mechanical, perfunctory, and merely ritualistic, failing the statutory safeguard under s.153D. Consequently, the assessments founded on such symbolic approval were vitiated and were quashed, and the appeal was allowed. - ITAT
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