UMESH SADASHIV THAKRE ,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1), NAGPUR

119 of the Act. Para-9 of Chapter-3 of Volume-II (Technical) of the Manual reads as under: - “9. Approval for assessment: An assessment order under Chapter XIV-B can be passed only with the previous approval of the range JCIT/ADDL.CIT (For the period from 30-6-1995 to 31-12-1996 the approving authority

UMESH SADASHIV THAKRE ,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

119 of the Act. Para-9 of Chapter-3 of Volume-II (Technical) of the Manual reads as under: - “9. Approval for assessment: An assessment order under Chapter XIV-B can be passed only with the previous approval of the range JCIT/ADDL.CIT (For the period from 30-6-1995 to 31-12-1996 the approving authority

ATUL MANOHARRAO YAMSANWAR,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 2(1), NAGPUR

68, which is ignored by the Addl.CIT while granting such mechanical approval. He has not even cared that in the absence of required satisfaction note“ for each year separately, entire assessment under section 153C would be vitiated. 60. In the present case before us, we noted that the Addl.CIT did not mention anything in the approval order passed under

ATUL MANOHARRAO YAMSANWAR,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 2(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

119 of the Act. Para-9 of Chapter-3 of Volume-II (Technical) of the Manual reads as under: - “9. Approval for assessment: An assessment order under Chapter XIV-B can be passed only with the previous approval of the range JCIT/ADDL.CIT (For the period from 30-6-1995 to 31-12-1996 the approving authority

SUFALAM INFRA PROJECTS LTD ,NAGPUR vs. PR. CIT (CENTRAL ), NAGPUR

In the result, the departmental appeal is dismissed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

119; or (d) the order has not been passed in accordance with any decision which is prejudicial to the assessee, rendered by the jurisdictional High Court or Supreme Court in the case of the assessee or any other person." This amendment will take effect from 1st day of June, 2015." Now, as can be seen above, the amendment to section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), NAGPUR, NAGPUR vs. M/S. SUFLAM INFRA PROJECT LTD, NAGPUR

In the result, the departmental appeal is dismissed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

119; or (d) the order has not been passed in accordance with any decision which is prejudicial to the assessee, rendered by the jurisdictional High Court or Supreme Court in the case of the assessee or any other person." This amendment will take effect from 1st day of June, 2015." Now, as can be seen above, the amendment to section

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. ACIT CENTRAL CIRCLE-1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment

ATUL MANOHARRAO YAMSANWAR,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 2(1), NAGPUR

119 of the Act. Para-9 of Chapter-3 of Volume-II (Technical) of the\nManual reads as under: -\n“9. Approval for assessment: An assessment order under Chapter XIV-B can be\npassed only with the previous approval of the range JCIT/ADDL.CIT (For the\nperiod from 30-6-1995 to 31-12-1996 the approving authority

YRCE EDUCATE PVT. LTD,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1), NAGPUR

119 of the Act. Para-9 of Chapter-3 of Volume-II (Technical) of the\nManual reads as under: -\n“9. Approval for assessment: An assessment order under Chapter XIV-B can be\npassed only with the previous approval of the range JCIT/ADDL.CIT (For the\nperiod from 30-6-1995 to 31-12-1996 the approving authority

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR vs. DEEPAK SURESH GADGE, NAGPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri K.M. Roy, Hon’Ble Accountant, Member

section 69C of the Act. 5. Aggrieved by the order of the Assessing Officer, Assessee preferred an appeal before the Ld.CIT(A) and filed his submissions. After considering the submissions of the Assessee, Ld.CIT(A) allowed the appeal of the Assessee. 6. Being aggrieved by the order of the Ld.CIT(A), Revenue is in appeal before us by raising

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR vs. DEEPAK SURESH GADGE, NAGPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri K.M. Roy, Hon’Ble Accountant, Member

section 69C of the Act. 5. Aggrieved by the order of the Assessing Officer, Assessee preferred an appeal before the Ld.CIT(A) and filed his submissions. After considering the submissions of the Assessee, Ld.CIT(A) allowed the appeal of the Assessee. 6. Being aggrieved by the order of the Ld.CIT(A), Revenue is in appeal before us by raising

M/S MAHESHWARI COAL BENEFICATION& INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

119. We thus record our conclusions as follows: B. Both section 153A and 153C embody non-obstante clauses and are in express terms ordained to override sec139, 147 to 149, 151 and 153. By virtue of the 2017 Amending Act, significant amendments came to be introduced in section 153A. These included, inter alia, the search assessment block being

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

119. We thus record our conclusions as follows: B. Both section 153A and 153C embody non-obstante clauses and are in express terms ordained to override sec139, 147 to 149, 151 and 153. By virtue of the 2017 Amending Act, significant amendments came to be introduced in section 153A. These included, inter alia, the search assessment block being

M/S MAHESHWARI COAL BENEFICATION& INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant Mmber

119. We thus record our conclusions as follows: B. Both section 153A and 153C embody non-obstante clauses and are in express terms ordained to override sec139, 147 to 149, 151 and 153. By virtue of the 2017 Amending Act, significant amendments came to be introduced in section 153A. These included, inter alia, the search assessment block being