Assessment proceedings invalidated due to improper Section 153D approval covering multiple years instead of separate yearly approvals

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ITAT quashed proceedings initiated under Section 153C read with Section 143(3) due to invalid approval under Section 153D. The Tribunal held that approval must be obtained separately for each assessment year and cannot be a common approval covering multiple years. Following the precedent in PCIT Central vs. Appellant, ITAT ruled that conjoint reading of Section 153A(1) and Section 153D mandates assessment officer obtain specific approval for each assessment year's draft assessment order before passing final orders under Section 153A. The mechanical approval covering all years collectively was deemed insufficient, requiring separate approvals respecting individual assessment years within the six-year period, thereby invalidating the entire assessment proceedings for lack of proper statutory compliance.....