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    <title>2025 (12) TMI 1765 - ITAT RAIPUR</title>
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    <description>The dominant issue was whether approval under s.153D was valid or was accorded mechanically without independent application of mind. The ITAT held that while the statute does not require elaborate reasons, the approving authority must record at least minimal indication of independent consideration. Here, the approval contained no reasoning and reflected borrowed satisfaction from the AO across multiple assessees and assessment years, defeating the legislative safeguard under s.153D. Consequently, the approval was void, and all consequential assessment proceedings founded on it were rendered non est in law; the assessee&#039;s appeal was allowed.</description>
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      <title>2025 (12) TMI 1765 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=784225</link>
      <description>The dominant issue was whether approval under s.153D was valid or was accorded mechanically without independent application of mind. The ITAT held that while the statute does not require elaborate reasons, the approving authority must record at least minimal indication of independent consideration. Here, the approval contained no reasoning and reflected borrowed satisfaction from the AO across multiple assessees and assessment years, defeating the legislative safeguard under s.153D. Consequently, the approval was void, and all consequential assessment proceedings founded on it were rendered non est in law; the assessee&#039;s appeal was allowed.</description>
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