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Issues: Whether the assessment made under section 153C read with section 143(3) of the Income-tax Act, 1961 was valid when the approval under section 153D was alleged to have been granted mechanically and without application of mind.
Analysis: The additional ground challenging the approval under section 153D was admitted as it went to the root of jurisdiction. The approval was found to be common for multiple assessees and multiple years, with no indication that the assessment records or incriminating material were examined. The approval requirement under section 153D is mandatory and must reflect conscious application of mind to the relevant record; a mechanical approval does not satisfy the statutory mandate.
Conclusion: The approval under section 153D was held invalid, the jurisdictional challenge succeeded, and the assessment order was quashed.