https://www.taxtmi.com/caselaws?id=306650 Rule 27 of the Income Tax (Appellate Tribunal) Rules, 1963 allows a respondent to support a favourable order on a ground decided against him where that ground goes to the sustainability of the relief granted, so the assessee could raise the jurisdictional objection. Section 153D approval must be a real, informed prior approval based on conscious consideration of the assessment record, seized material and draft order; mechanical approval without application of mind fails the statutory mandate and vitiates the assessment. The assessments were therefore quashed and the Revenue's appeals failed without examination of the additions on merits. en-us Thu, 25 Nov 2021 00:00:00 +0530 Thu, 16 Feb 2023 20:54:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306650 Rule 27 of the Income Tax (Appellate Tribunal) Rules, 1963 allows a respondent to support a favourable order on a ground decided against him where that ground goes to the sustainability of the relief granted, so the assessee could raise the jurisdictional objection. Section 153D approval must be a real, informed prior approval based on conscious consideration of the assessment record, seized material and draft order; mechanical approval without application of mind fails the statutory mandate and vitiates the assessment. The assessments were therefore quashed and the Revenue's appeals failed without examination of the additions on merits. Case-Laws Income Tax Thu, 25 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306650