TaxTMI 
TaxTMI 
Scrutinizing the Application of Mind in Tax Assessments: Examining the Role of ACIT while granting approval u/s 153D
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.... profound exploration into the procedural and substantive aspects of tax assessments under the Income Tax Act, 1961. This case serves as a paradigmatic example of how courts scrutinize the application of mind by tax authorities, specifically focusing on the role of the Additional Commissioner of Income Tax (ACIT) in granting approvals under Section 153D of the Act. Contextual Framework The appea....
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....revolved. * Critical Examination of ACIT's Approval: The crux of the dispute lay in the extent and nature of the application of mind by the ACIT in granting approval under Section 153D. The Tribunal highlighted a glaring lack of scrutiny in the approval process, leading to significant discrepancies in income assessment. * Inconsistencies in Income Assessment: The AO's additions to ....
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....nting approval rendered the assessment order invalid. This decision reflects the judiciary's commitment to ensuring that procedural norms are not just followed in form but also in substance. * Absence of Substantial Question of Law: The High Court aligned with the Tribunal in concluding that the case did not give rise to a substantial question of law, as the issues were primarily factual, ....