#Section 153D

The ITAT Surat Bench set aside assessment orders for AY 2011-14 because the Commissioner of Income-Tax (Appeals) failed to obtain the mandatory prior approval of the Joint Commissioner under Section 153D. The ruling makes it clear that any assessment under special provisions is invalid without such approval, impacting both taxpayers and revenue officials.

The ITAT Dehradun has ruled that a single, mechanical approval covering multiple assessees under Section 153D lacks legal validity, quashing assessments issued without individualized sanction. This sets a critical precedent for tax officers: blanket approvals cannot substitute statutorily mandated personal scrutiny, impacting all pending and future joint assessments under the Income Tax Act.

ITAT Delhi rules that a combined approval under Section 153D for multiple assessment years renders search-based assessments invalid. The decision reinforces procedural compliance as jurisdictional, impacting all search assessments requiring individual approvals.

ITAT Delhi quashed an assessment order where the JCIT's approval under Section 153D was mechanical, lacked application of mind, and omitted mandatory DIN compliance. The ruling reinforces that digital evidence protocols and natural justice principles must govern search assessments to prevent arbitrary tax proceedings.