https://www.taxtmi.com/caselaws?id=773348 ITAT Raipur quashed assessment proceedings where competent authority granted approval under Section 153D mechanically without application of mind. The approval was issued on same date as request with generic language "you may act accordingly" without any findings or reasoning for granting seven-year approval. Court relied on Delhi HC precedents in Shiv Kumar Nayyar and MDLR Hotels cases establishing that mechanical approvals without independent examination defeat Section 153D's purpose. ITAT held that competent authority must examine case records for each assessment year and demonstrate independent application of mind, even if exhaustive reasons aren't mandatory. Since approval was granted in summary manner based on borrowed satisfaction from AO, subsequent proceedings were declared non-est. Assessee's appeal was allowed. en-us Wed, 21 May 2025 00:00:00 +0530 Sat, 21 Jun 2025 08:28:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773348 ITAT Raipur quashed assessment proceedings where competent authority granted approval under Section 153D mechanically without application of mind. The approval was issued on same date as request with generic language "you may act accordingly" without any findings or reasoning for granting seven-year approval. Court relied on Delhi HC precedents in Shiv Kumar Nayyar and MDLR Hotels cases establishing that mechanical approvals without independent examination defeat Section 153D's purpose. ITAT held that competent authority must examine case records for each assessment year and demonstrate independent application of mind, even if exhaustive reasons aren't mandatory. Since approval was granted in summary manner based on borrowed satisfaction from AO, subsequent proceedings were declared non-est. Assessee's appeal was allowed. Case-Laws Income Tax Wed, 21 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773348