https://www.taxtmi.com/caselaws?id=797001 Section 153D prior approval is a mandatory safeguard in search assessments, requiring an independent, quasi-judicial examination of draft assessment orders, seized material, enquiries and taxpayer replies. Approval spanning multiple assessees and assessment years without showing consideration of relevant records or incriminating material is characterised as mechanical. For non-abated years, additions based on financial material and Form 3CD rather than incriminating material further indicate non-application of mind. Section 292BC applies only to approvals granted on or after 1 April 2021 and does not validate earlier approvals. Mechanical Section 153D approval vitiates assessments framed pursuant to it. en-us Thu, 30 Jul 2026 00:00:00 +0530 Fri, 14 Aug 2026 07:18:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797001 Section 153D prior approval is a mandatory safeguard in search assessments, requiring an independent, quasi-judicial examination of draft assessment orders, seized material, enquiries and taxpayer replies. Approval spanning multiple assessees and assessment years without showing consideration of relevant records or incriminating material is characterised as mechanical. For non-abated years, additions based on financial material and Form 3CD rather than incriminating material further indicate non-application of mind. Section 292BC applies only to approvals granted on or after 1 April 2021 and does not validate earlier approvals. Mechanical Section 153D approval vitiates assessments framed pursuant to it. Case-Laws Income Tax Thu, 30 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797001