In the result, the all the appeals of the assessees are allowed
Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm
reassessment order, as the case may be, is required to be passed by the Assessing Officer with the prior approval of the [Principal Commissioner or Commissioner] under sub-section (12) of Section 144-BA." 11. A plain reading of the aforesaid provision evinces an uncontrived position of law that the approval under Section 153D