https://www.taxtmi.com/caselaws?id=774982 The ITAT Pune held that assessment proceedings under section 153C were invalid due to procedural violations. The AO passed a combined satisfaction note for multiple assessment years, which the SC in DCIT v. Sunil Kumar Sharma ruled requires separate satisfaction notes for each year. Additionally, the approval under section 153D was granted mechanically by the JCIT/Addl.CIT without proper application of mind, as evidenced by the automatic treatment of cheque payments as on-money cash payments. The tribunal found that mechanical approval under section 153D vitiates assessment proceedings and renders them contrary to law. Consequently, the assessment orders were quashed and the assessee's appeal was allowed, establishing that both proper satisfaction recording and meaningful approval are mandatory procedural requirements. en-us Mon, 14 Jul 2025 00:00:00 +0530 Tue, 15 Jul 2025 15:52:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774982 The ITAT Pune held that assessment proceedings under section 153C were invalid due to procedural violations. The AO passed a combined satisfaction note for multiple assessment years, which the SC in DCIT v. Sunil Kumar Sharma ruled requires separate satisfaction notes for each year. Additionally, the approval under section 153D was granted mechanically by the JCIT/Addl.CIT without proper application of mind, as evidenced by the automatic treatment of cheque payments as on-money cash payments. The tribunal found that mechanical approval under section 153D vitiates assessment proceedings and renders them contrary to law. Consequently, the assessment orders were quashed and the assessee's appeal was allowed, establishing that both proper satisfaction recording and meaningful approval are mandatory procedural requirements. Case-Laws Income Tax Mon, 14 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774982