https://www.taxtmi.com/caselaws?id=772673 The ITAT Delhi held that JCIT's approval under section 153D was mechanical and invalid due to lack of application of mind. The JCIT merely stated "the above draft assessment order is hereby accorded approval" without verifying assessment records or seized documents. Additionally, the AO passed the assessment order on the same date as approval, which was practically unfeasible. The tribunal emphasized that statutory approval cannot be treated as mere formality and requires judicious consideration by the approving authority acting in quasi-judicial capacity. The mechanical approval defeated the legislative mandate, rendering it legally invalid. Decision favored the assessee. en-us Wed, 23 Apr 2025 00:00:00 +0530 Tue, 10 Jun 2025 18:41:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772673 The ITAT Delhi held that JCIT's approval under section 153D was mechanical and invalid due to lack of application of mind. The JCIT merely stated "the above draft assessment order is hereby accorded approval" without verifying assessment records or seized documents. Additionally, the AO passed the assessment order on the same date as approval, which was practically unfeasible. The tribunal emphasized that statutory approval cannot be treated as mere formality and requires judicious consideration by the approving authority acting in quasi-judicial capacity. The mechanical approval defeated the legislative mandate, rendering it legally invalid. Decision favored the assessee. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772673