https://www.taxtmi.com/caselaws?id=465477 Assessments framed u/s 153A were challenged as void for want of valid prior approval u/s 153D. The ITAT held that approval u/s 153D is justiciable and must reflect independent application of mind to the draft order, applicable law, and relevant material; a non-speaking, omnibus approval for multiple assessees/years violates the requirement of separate, year-wise approval and CBDT's binding instructions under s 119 to provide adequate time and opportunity before the time-bar date. On facts, the common approval letter showed rubber-stamping, with no credible record of materials considered. Consequently, the u/s 153D approval was invalid and the entire u/s 153A assessment was vitiated and annulled, with no extension of limitation available to cure the defect. en-us Tue, 30 Sep 2025 00:00:00 +0530 Fri, 26 Dec 2025 14:15:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465477 Assessments framed u/s 153A were challenged as void for want of valid prior approval u/s 153D. The ITAT held that approval u/s 153D is justiciable and must reflect independent application of mind to the draft order, applicable law, and relevant material; a non-speaking, omnibus approval for multiple assessees/years violates the requirement of separate, year-wise approval and CBDT's binding instructions under s 119 to provide adequate time and opportunity before the time-bar date. On facts, the common approval letter showed rubber-stamping, with no credible record of materials considered. Consequently, the u/s 153D approval was invalid and the entire u/s 153A assessment was vitiated and annulled, with no extension of limitation available to cure the defect. Case-Laws Income Tax Tue, 30 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465477