Income Tax Assessments on Basis of Consolidated Approval u/s 153D is Void Ab Initio: ITAT

The Income Tax Appellate Tribunal (ITAT) has ruled that an "income tax assessment is 'void ab initio'" if it is "based on a consolidated approval under Section 153D." The tribunal found that the Assessing Officer had sought a single, blanket approval for the assessment of multiple individuals and entities, instead of a separate, reasoned approval for each case. The ITAT emphasized that the law requires a distinct and independent application of mind for each assessee, and a consolidated approach is a fundamental procedural lapse that vitiates the entire assessment. This judgment sets a critical precedent, ensuring that tax authorities adhere to strict legal protocols when conducting assessments.