https://www.taxtmi.com/caselaws?id=459288 The ITAT Delhi held that approval under section 153D was invalid due to mechanical exercise of quasi-judicial authority. The approving authority used identical language and reasoning for different assessees, granting approvals on different dates without proper examination of assessment records and draft orders. The tribunal emphasized that approval requires actual consideration of incriminating material and evidentiary value, not mere formality. The use of standard phrases about mandatory compliance cannot justify approval orders without demonstrating genuine examination of the AO's findings and material relied upon for income concealment conclusions. en-us Mon, 30 Sep 2024 00:00:00 +0530 Sat, 07 Dec 2024 08:11:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459288 The ITAT Delhi held that approval under section 153D was invalid due to mechanical exercise of quasi-judicial authority. The approving authority used identical language and reasoning for different assessees, granting approvals on different dates without proper examination of assessment records and draft orders. The tribunal emphasized that approval requires actual consideration of incriminating material and evidentiary value, not mere formality. The use of standard phrases about mandatory compliance cannot justify approval orders without demonstrating genuine examination of the AO's findings and material relied upon for income concealment conclusions. Case-Laws Income Tax Mon, 30 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459288