prior approval is necessary for a valid assessment under Section 153A and 153C.

Section 153D of the act in the present Search Assessment regime mandates that a prior approval is necessary for a valid assessment under Section 153A and 153C. The Legislative intent can be gathered from the CBDT Circular No. 3 of 2008, dated 12.3.2008, which read as under: Assessment of search cases Orders of assessment and reassessment to be approved by the Joint Commissioner. The existing provisions of making assessment and. reassessment in cases where search has been conducted under section 132 or requisition is made under section. 132A does not provide for any approval for such assessment.