Section 153D Approval Invalid: Tax Officials Failed to Review Complex Documentation Within Unrealistic Timeline for 35 Cases

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....ITAT invalidated approval granted under s153D due to lack of proper application of mind by Addl. CIT. The approval, though conditional with directions, was deemed mechanically processed given the impractical timeframe for reviewing extensive documentation across 35 cases. The geographical distance between Dehradun (AO's location) and Meerut (Addl. CIT's office) necessitated physical transfer of voluminous records including assessment orders, appraisal reports, and seized materials. ITAT found it humanly impossible for Addl. CIT to meaningfully examine multiple complex cases, each containing substantial documentation, within days. The tribunal concluded the approval process was procedurally defective, ruling in favor of the assessee.....