Valid section 153D approval is essential for 153A assessments; composite sanction defect led to quashing.

An additional ground challenging the assessment for lack of valid approval under section 153D was admitted because it went to the root of the matter and the relevant facts were already on record. On merits, the assessment records showed that the Assessing Officer sought a common approval for multiple assessment years, and the sanction granted covered the year in question as part of a composite approval. That defect in the approval process was treated as going to the validity of the assessment itself, and the assessment framed under section 143(3) read with section 153A was quashed for want of valid section 153D approval.

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Issues: Whether the assessment framed under section 143(3) read with section 153A was vitiated for want of valid approval under section 153D, and whether the assessee could raise the additional ground challenging the assessment on that basis.

Analysis: The additional ground was admitted as it went to the root of the matter and the relevant facts were already on record. On the merits, the assessment records showed that the Assessing Officer sought a common approval for multiple assessment years and the approval so granted covered the present year as part of a composite sanction. The defect in the manner of approval was held to strike at the validity of the assessment itself.

Conclusion: The assessment was held invalid for want of a valid section 153D approval and was quashed. The assessee succeeded and the Revenue's appeal failed.

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