2025 (12) TMI 1049

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....ces of the case, the Hon'ble ITAT is justified in raising the presumption that the approval u/s 153D is mechanical without application of mind and without considering the merits of the additions suggested by the assessing officer, stating that no satisfaction has been recorded by the additional commissioner before according approval when there is no such requirement of recording satisfaction prescribed in the Act?" 3. However, later on, Ms. Punamiya the learned Counsel for the Respondent pointed out that the issue involved in this Appeal is covered by decisions of various High Courts and Special Leave Petitions against some of them have already been dismissed. Accordingly, we posted this matter on 10 December 2025 for direction/dispo....

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....lowed by Special Audit conducted under Section 142(2A) of the Act. He submitted that even statements of the assessee were recorded. He also submitted that most of the additions were made based on the Special Audit Report. He further submitted that despite opportunities, the assessee offered no clarification and submitted no details. 9. Based on the above, Mr. Sharma submitted that the approval dated 6 August 2010 was granted in the above circumstances and on the above material. He submitted that the approval order is not required to be like some reasoned or order. 10. Although, it is correct that the approval order is not required to resemble a reasoned judgment or order, such approval order should reflect at least a minimum applicati....