Resonance Eduventures Ltd. v. ACIT (2025) 235 TTJ 370 (Jaipur)(Trib)

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]

Held that the Addl. CIT having approved s. 153D for 200 cases, including the assessee’s case, in one day itself, and there being no indication of examination of the assessment records or the search material, it is clear that the impugned approval has been granted in a mechanical manner and without application of mind and, therefore, the same is invalid and bad in law and consequently, the assessment under s. 153A is vitiated for want of valid approval under s. 153D. (AY. 2015-16 to 2018-19)

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