Assessment based on Section 153D approval in mechanical manner without application of mind is invalid

Rajesh Ladhani Vs DCIT (ITAT Agra) It is evident from the  CBDT Circular No. 3 of 2008, dated 12.3.2008 that the legislature in its highest wisdom made it compulsory that the assessments of search cases should be made with the prior approval of superior authority, so that the superior authority apply their mind on the materials and other attending circumstances on the basis of which the officer is making the assessment and after due application of mind and on the basis of seized materials, the superior authority have to approve the Assessment order. Object of entrusting the duty of Approval o...