Bombay HC Quashed Reassessment for Mechanical Section 153D Approval

PCIT-1 Vs Vrushali Sanjay Shinde (Bombay High Court)

The Bombay High Court dismissed the Revenue’s appeal and affirmed the decision of the Income Tax Appellate Tribunal (ITAT) holding that a mechanical approval under Section 153D of the Income-tax Act vitiates proceedings initiated under Section 153C. The appeal had been admitted to consider whether the ITAT was justified in presuming that the statutory approval was mechanical and without application of mind, even though the Act does not expressly require the approving authority to record satisfaction.

The

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