Mechanical Approval U/s 153D Vitiates Entire U/s 153C Assessment – All Years Quashed

Pack Plast India Pvt. Ltd Vs DCIT (ITAT Delhi) ITAT Delhi quashed assessments for AYs 2014-15, 2016-17 & 2017-18 framed u/s 153C, holding that the mandatory approval u/s 153D was granted in a mechanical, ritualistic manner without independent application of mind. Though separate approval letters were issued for each year, all were identically worded, same-dated and revealed that the approving authority did not personally examine the seized material, but merely relied on what was “perused by the AO and brought to notice”. The Tribunal held that approval u/s 153D is not an empty formalit...