In the result, the appeals of the assessee are allowed and those of Revenue are
Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena
penalty was held as procedurally defective. The provisions laid down u/s. 153D of the Act under consideration in the present case before us, are different as here the prior approval of Joint Commissioner is not required merely for direction for payment of the due amount of tax but overall approval of the assessment framed by the I.T.O. Thus, the cited