Section 153D approval must reflect independent application of mind; mechanical rubber-stamping can vitiate the assessment.

Prior approval under section 153D must show independent application of mind to each draft assessment order for every assessment year. Where the approval is verbatim across years, uses vague language such as "as amended," and does not indicate scrutiny of the draft order, the electronic evidence, or the basis of additions, it is treated as a mere formality rather than a valid statutory exercise. Such mechanical or ritualistic approval vitiates the assessment order and any consequential additions.

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Issues: Whether the approval granted under section 153D of the Income-tax Act, 1961 was mechanical and without application of mind, thereby vitiating the assessment and consequential additions.

Analysis: The approval records were found to be verbatim in respect of multiple assessment years and contained the ambiguous expression "as amended", without showing any independent examination of the draft assessment orders. The assessment was heavily based on electronic material, yet the approval did not reflect any verification of the manner in which such digital evidence was collected, tested, linked, or analyzed. The record also did not show meaningful scrutiny of the working behind the additions. In these circumstances, the prior approval was treated as a mere formality and not an exercise of independent statutory discretion. The requirement under section 153D was held to demand application of mind for each assessment year and cannot be reduced to rubber stamping.

Conclusion: The approval under section 153D was invalid for want of application of mind and the assessment order stood vitiated.

Ratio Decidendi: Prior approval under section 153D must reflect independent application of mind to the draft assessment order for each assessment year, and a mechanical or ritualistic approval vitiates the assessment.

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