S. 153A: Assessment-Search-Approval should not be rubber-stamping and mere ritual formality and should not suffer from lack of application of mind-The Addl. CIT also granted approval under s. 1 on the very same day, in the other 12 cases-The approving authority has not applied his mind and granted the approval in a mechanical and hasty manner-Approval suffers from perversity and impropriety-The approval is invalid in the eyes of law, and consequently the assessment order is also invalid.[S. 153D]

S. 153A: Assessment-Search-Incriminating material-Time limit for issue of notice u/s 143(2) as on date of search has not expired-The Assessing Officer had power to assessee / re assess the total income including undisclosed income-Appellate Tribunal-Cross objection-Delay of 205 days was condoned-Undisclosed income-Accommodation entries-Addition cannot be made without providing the statement and an opportunity of cross examination-Sub contractor-No opportunity of cross examination-Addition was deleted. [S. 132, 143(2), 254(1)]

S. 153A: Assessment-Search-Approval under S. 153D-Approving authority granted approval by a letter without even a token of mention of any independent application of mind-200 cases without application of mind-Invalid and bad in law-The assessment is vitiated for want of valid approval under s. 153D.[S.132, 153D]

S. 153A: Assessment-Search-AO cannot take into consideration the material collected at the premises of a third person without following the mandatory procedure contemplated in S. 153C-Satisfaction not recorded-Addition was deleted-[S.132(4), 153C]

S. 153A: Assessment-Search-Computation of undisclosed income-Addition is sustained to the extent of Rs. 10 lakh in addition to the income already disclosed voluntarily by the assessee. [S. 132, 144]

S. 151: Reassessment-Sanction for issue of notice-Limitation-Information-Mere generation of notice on the ITBA screen cannot in fact or in law constitute issue of notice-Cash deposit-The AO has failed to establish with concrete information that there is escapement of income-Notice was issued after obtaining the approval from Jt. CIT and not with the approval of the prescribed authority-Reassessment notice and consequential order are quashed. [S. 147, 148, 148A(b)]

S. 151: Reassessment-Sanction for issue of notice-Specified authority-Sanction form Principal CIT and not Chief CIT-Reopening proceedings and the reassessment order passed are quashed.[S. 151(ii)]

S. 149: Reassessment-Time limit for notice-Notice issued after expiry of six years from the end of relevant assessment year-Notice for asst. yr. 2015-16 issued on 15th July, 2022 under s. 148 is barred by limitation, hence bad in law [S. 148]

S. 149: Reassessment-Time limit for notice-Cash deposit-The AO assumed jurisdiction by passing an order under s. 148A(d) on the basis of incorrect information-Notice beyond three years from the end of the relevant assessment year-The notice issued by the AO under S. 148 dt. 28th April, 2022, is illegal, void ab initio and consequently, the assessment order passed was quashed. [S. 143(3), 147, 148, 148A(b), 148A(d)]

S. 147 : Reassessment-Search-Loose papers-Satisfaction-The Assessing Officer ought to have initiated action under section 153C-Reassessment was quashed and set aside. [S. 132, 148, 153C]