Invalid Section 153D approval can vitiate Section 153A assessment where sanction is mechanical and non-speaking.

Section 153D approval must reflect independent application of mind to each assessment year and the relevant draft order, records and seized material. A common approval note covering multiple cases and years, without showing such examination, is an omnibus and ritualistic sanction that does not satisfy the statutory safeguard. On that basis, the assessment framed under Section 153A could not stand, and the assessment order was quashed for invalid approval under Section 153D.

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Issues: Whether the assessment framed under Section 153A was liable to be quashed on the ground that approval under Section 153D was granted mechanically and without application of mind.

Analysis: The approval note granted by the approving authority covered multiple cases and assessment years in a single communication and did not indicate any examination of the draft assessment order, assessment records, or seized material. The approval was therefore treated as an omnibus and ritualistic sanction rather than an independent consideration of each assessment year. In such a situation, the statutory safeguard under Section 153D is not satisfied, and the assessment based on such approval cannot stand.

Conclusion: The approval under Section 153D was invalid for want of application of mind, and the assessment order was quashed. The issue is decided in favour of the assessee.

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