Treatment of S. 153D Income Tax Act as pari-materia to S. 148 mechanism by AO without Approval: ITAT remands 49 Appeals to CIT(A)

The Income Tax Appellate Tribunal (ITAT) remanded 49 appeals back to the Commissioner of Income Tax (Appeals) [CIT(A)] after finding that the Assessing Officer (AO) had incorrectly applied the procedure under Section 153D of the Income Tax Act, treating it as similar to Section 148, which deals with income escaping assessment. The AO had conducted the assessments without obtaining the necessary approvals, leading to the appeals. The ITAT’s decision to remand the cases underscores the importance of following the correct procedural steps in tax assessments to ensure that taxpayers' rights are protected.