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    <title>2021 (8) TMI 1446 - ITAT LUCKNOW</title>
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    <description>The dominant issue was whether approval under s.153D for completing search assessments was vitiated as mechanical and without independent application of mind. The Tribunal held that s.153D requires approval in respect of &quot;each&quot; assessment, and the grant of approval for 67 cases on the same date was inherently indicative of non-examination of the draft orders, making meaningful scrutiny humanly impossible. Relying on HC authority holding that approval without consideration of issues is invalid, the Tribunal treated the statutory approval as legally defective. Consequently, the impugned assessments framed pursuant to such invalid s.153D approval could not stand, and relief was granted to the assessee.</description>
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      <title>2021 (8) TMI 1446 - ITAT LUCKNOW</title>
      <link>https://www.taxtmi.com/caselaws?id=465503</link>
      <description>The dominant issue was whether approval under s.153D for completing search assessments was vitiated as mechanical and without independent application of mind. The Tribunal held that s.153D requires approval in respect of &quot;each&quot; assessment, and the grant of approval for 67 cases on the same date was inherently indicative of non-examination of the draft orders, making meaningful scrutiny humanly impossible. Relying on HC authority holding that approval without consideration of issues is invalid, the Tribunal treated the statutory approval as legally defective. Consequently, the impugned assessments framed pursuant to such invalid s.153D approval could not stand, and relief was granted to the assessee.</description>
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