Section 153D approval must be case-specific; common sanction without independent application of mind invalidates assessment proceedings.

Approval under section 153D must reflect independent, case-specific application of mind to each draft assessment order; a common, non-individualised sanction for multiple assessees and years is invalid. Where the record does not show separate perusal of the draft orders or meaningful consideration of each case, the defect goes to the root of the proceedings and the assessments framed under sections 153A and 153C are quashed.

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Issues: Whether the assessment framed under sections 153A and 153C could survive when the approval under section 153D was granted in a common, non-individualised manner without demonstrable independent consideration of the draft assessment orders.

Analysis: The approval recorded one sanction for multiple assessees and multiple assessment years. The record did not show that the draft assessment orders were separately perused or that the approving authority applied its mind to each case independently. In view of the settled requirement that approval under section 153D must be a meaningful and case-specific sanction, the deficiency went to the root of the assessment proceedings.

Conclusion: The approval under section 153D was held invalid for want of independent application of mind, and the assessment framed under sections 153A and 153C was quashed.

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