Dismissing the appeal the Court held that having regard to the findings returned by the Tribunal, which were findings of fact, no substantial question of law arose for consideration. The Tribunal was right that there was absence of application of mind by the Additional Commissioner in granting approval under section 153D of the Income-tax Act, 1961. It was not an exercise dealing with an immaterial matter which could be corrected by recourse to section 292B of the Act. The order of assessment under section 153A read with section 143(3) was not valid. (AY.2017-18)