https://www.taxtmi.com/caselaws?id=767341 The dominant issue was whether the assessment under s.143(3) was vitiated for lack of independent application of mind. The HC held that the AO's repeated consultations with superior officers and the comprehensive participation of the approving authority went beyond permissible approval and effectively amounted to directions, resulting in abdication of statutory discretion; the assessment was therefore vitiated and non est, leading to its quashing. The HC also held that principles of natural justice were breached because no fair and reasonable opportunity of hearing was given after the reply, rendering the order illegal and arbitrary; the assessment was liable to be set aside. On limitation, the HC found no assessment was made within the statutory period and rejected any saving based on portal/email assertions; the order was time-barred and was quashed. en-us Fri, 07 Mar 2025 00:00:00 +0530 Tue, 30 Dec 2025 16:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767341 The dominant issue was whether the assessment under s.143(3) was vitiated for lack of independent application of mind. The HC held that the AO's repeated consultations with superior officers and the comprehensive participation of the approving authority went beyond permissible approval and effectively amounted to directions, resulting in abdication of statutory discretion; the assessment was therefore vitiated and non est, leading to its quashing. The HC also held that principles of natural justice were breached because no fair and reasonable opportunity of hearing was given after the reply, rendering the order illegal and arbitrary; the assessment was liable to be set aside. On limitation, the HC found no assessment was made within the statutory period and rejected any saving based on portal/email assertions; the order was time-barred and was quashed. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767341