2026 (1) TMI 939

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....GR/2025 for AY 2010-11, arises out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as "ld. NFAC", in short] dated 08.05.2024 against the order of assessment passed u/s 144/147 of the Income-tax Act, 1961 (hereinafter referred to as "the Act") dated 21.12.2017 by the Assessing Officer, Income Tax Officer, Ward-3(2), Etah (hereinafter referred to as "ld. AO....

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....ade in the savings bank account of the assessee in the sum of Rs 12 lakhs. The assessee was queried to explain the source of such cash deposits. The assessee responded that he is an agriculturist and that the cash deposits were made out of sale proceeds of agriculture produce and submitted his PAN to be EKYPS0396P. The assessee also furnished the entire land records together with the patta and als....

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....the notice u/s 148". This sort of approval granted u/s 151 of the Act was held to be approval granted without application of mind and construed as mechanical by the Hon'ble Madhya Pradesh High Court in the case of CIT Vs. S. Goyenka Lime and Chemicals Ltd reported in 56 taxmann.com 390 (MP HC). The Special Leave Petition (SLP) filed by the revenue against this decision was dismissed by the Hon&#39....

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....ecord elaborate reasons for agreeing with the noting put up. At the same time, satisfaction has to be recorded of the given case which can be reflected in the briefest possible manner. In the present case, the exercise appears to have been ritualistic and formal rather than meaningful, which is the rationale for the safeguard of an approval by a higher ranking officer. For these reasons, the Court....