Section 153D approval must be case-specific; consolidated mechanical sanction for multiple assessees and years is invalid.

Section 153D approval must be granted after independent application of mind for each assessee and each assessment year; a consolidated approval covering multiple assessees and years, without separate consideration of the draft order and record in each case, is mechanical and does not satisfy the statutory mandate. On that basis, the approval was treated as invalid and the assessments were quashed.

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Issues: Whether the approval granted under section 153D was valid when a consolidated approval was issued for multiple assessees and multiple assessment years, instead of a separate approval for each assessment year and each assessee.

Analysis: Section 153D requires prior approval before passing an assessment order under the search assessment provisions, and the approval must be examined with reference to each assessment year. A common approval covering several cases and several years, without separate consideration of the draft assessment order and material for each assessee and each year, defeats the statutory purpose. Such approval cannot be treated as a mere formality or rubber-stamp exercise, because the approving authority must apply an independent mind to the record before granting sanction.

Conclusion: The consolidated approval was held to be mechanical and invalid. The challenge to the assessment on this ground was accepted and the assessments were quashed.

Ratio Decidendi: Approval under section 153D must be granted after independent application of mind for each assessee and each assessment year; a common mechanical approval does not satisfy the statutory mandate.

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