Mechanical section 153D approval invalidates a section 153A assessment where sanction lacks application of mind.

An assessment framed under section 153A was quashed because the approval under section 153D was granted mechanically, without due application of mind to the search and scrutiny records. The Tribunal examined the approval folder and found that the sanction dated 27.03.2014 was issued through a common note, without meaningful consideration of the material before the prescribed authority. It held that such a mechanical sanction could not validly support the assessment, and the assessment was therefore invalid for want of proper section 153D approval.

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

Analysis: The approval folder was produced pursuant to the Tribunal's earlier direction. On examination of the record, the approval dated 27.03.2014 was found to have been given in a common note without meaningful consideration of the material placed before the prescribed authority. Such mechanical sanction under section 153D was held to be insufficient to sustain the assessment.

Conclusion: The assessment was quashed for want of valid, application-of-mind approval under section 153D, and the issue was decided in favour of the assessee.

Ratio Decidendi: Approval under section 153D must reflect due application of mind to the relevant material, and a mechanical sanction vitiates the assessment framed on its basis.

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