AO cannot treat section 153D as pari-materia to section 148 mechanism: ITAT Cochin

ABC Sales Corporation Vs ITO (ITAT Cochin)

ITAT Cochin held that treating section 153D of the Income Tax Act as pari-materia to section 148 mechanism without any such indication in the Act is unjustified and hence matter remanded back to CIT(A).

Facts- Apart from various other issues; the assessee had argued in the lower appellate proceedings that the impugned assessment had not been framed in due compliance to sec.153D of the Act requiring the Assessing Officer to obtain the statutory approval from the prescribed authority(ies).

Conclusion- <

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