Section 153D approval must reflect real application of mind, or search assessments become unsustainable.

Search assessments under section 153A require a valid supervisory approval under section 153D based on meaningful application of mind to the seized material and year-wise issues. Where the approval was granted in a consolidated, same-day, routine manner for multiple assessment years, with no demonstrable independent examination of the draft orders or records, the statutory mandate was not satisfied. The mechanical approval was therefore invalid, and the resulting assessments were treated as non-est and void; the assessee succeeded on the jurisdictional challenge and the assessment orders were quashed.

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Issues: Whether the assessments framed pursuant to search could survive where the approval under section 153D was granted in a consolidated manner on the same day as the draft orders, without demonstrable application of mind to the material and issues for each assessment year.

Analysis: The assessments arose from a search and were completed under section 153A after draft orders were placed before the approving authority under section 153D. The approval note disclosed only a routine grant of approval, with no indication that the seized material, assessment records, or year-wise issues were independently examined. The approval was common for multiple assessment years and was accorded on the very day the draft orders were forwarded, which supported the conclusion that the statutory supervisory function was not meaningfully discharged. Since section 153D requires a real and objective consideration of the proposed assessment, a blanket or mechanical approval does not satisfy the legal mandate.

Conclusion: The approval under section 153D was invalid, the assessments were non-est and void, and the assessee succeeded on the jurisdictional challenge.

Final Conclusion: The assessee's cross objections were allowed, the assessment orders were quashed, and the Revenue's appeals failed.

Ratio Decidendi: An approval under section 153D of the Income-tax Act, 1961 must be granted only after meaningful application of mind to the assessment material and year-wise issues; a mechanical or blanket approval renders the resulting search assessment unsustainable.

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