PCIT v. Shiv Kumar Nayyar
163 Taxmann.com 9High Court2024#100 most cited
What is PCIT v. Shiv Kumar Nayyar authority for?
Approval under Section 153D for search assessments is invalid if granted mechanically, hastily, or without due application of mind, such as on the same day as the proposal or in a bunched manner. Such an invalid approval renders the consequential assessment order under Section 153A void ab initio.
597
judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2024 to 2026.
Also referred to as
PCIT v. Shiv Kumar Nayyar · Section 153D approval · Section 153A assessment · validity of prior approval · mechanical approval · same-day approval · bunched approval · application of mind · search assessment void ab initio · 467 ITR 186
Also reported as
467 ITR 186299 Taxmann 385
