PCIT v. Anju Bansal (2024) 300 taxman 184/ 466 ITR 254 (SC) Editorial : PCIT v. Anju Bansal (2024) 165 taxmann.com 2 /466 ITR 251 (Delhi)(HC)

S. 153D : Assessment-Search-Approval-Mechanical approval-ACIT granted approval without noticing discrepancy in assessment order or search material-Mechanical approval without application of mind would be invalid in eyes of law. [S.132,153A Art. 136]

On the basis of  a search conducted at assessee’s premises Assessing Officer made significant additions to assessee’s income for cash deposits and cash introduced through an entry operator. Assessing Officer incorrectly recorded returned income, leading to an erroneous total assessed income. ACIT approved assessment under Section 153D without reviewing assessment records or search material, missing key discrepancies. On appeal, Tribunal set aside assessment order on ground that ACIT’s approval was based only on draft assessment order and failed to review assessment records and search material. High Court upheld Tribunal’s finding. SLP of Revenue is dismissed.(AY. 2013-14)

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