https://www.taxtmi.com/caselaws?id=434557 Section 153D mandates the AO to obtain prior approval of the Joint Commissioner on the draft assessment order for each assessment year covered by s.153A search assessments. On a conjoint reading of ss.153A(1) and 153D, year-wise approval is a condition precedent to a valid assessment order. Where draft orders for 38 assessment years (including other group cases) were placed before the approving authority and approved on the same day, the Tribunal's inference that approval was granted mechanically without independent application of mind was not perverse. Consequently, no substantial question of law arose in the second appeal, and the revenue's appeal was dismissed. en-us Mon, 12 Dec 2022 00:00:00 +0530 Fri, 26 Dec 2025 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434557 Section 153D mandates the AO to obtain prior approval of the Joint Commissioner on the draft assessment order for each assessment year covered by s.153A search assessments. On a conjoint reading of ss.153A(1) and 153D, year-wise approval is a condition precedent to a valid assessment order. Where draft orders for 38 assessment years (including other group cases) were placed before the approving authority and approved on the same day, the Tribunal's inference that approval was granted mechanically without independent application of mind was not perverse. Consequently, no substantial question of law arose in the second appeal, and the revenue's appeal was dismissed. Case-Laws Income Tax Mon, 12 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434557