Application of mind in tax approvals: inadequate ACIT scrutiny under Section 153D can invalidate assessments.
The core issue is whether the ACIT, when granting approval under Section 153D, performed a genuine application of mind by scrutinising assessment records and search material; the Tribunal and High Court found the approval lacked adequate examination, leading to inconsistencies between additions made by the assessing officer and the assessed income, and rendering the assessment unreliable. The matter was treated as factual rather than presenting a substantial question of law.