Section 153D approval requires separate mind to each assessment record; consolidated approval without scrutiny is invalid.

A consolidated approval under section 153D covering multiple assessees and assessment years was found invalid where it did not show independent examination of each assessee's assessment record. The analysis relied on coordinate Bench rulings that such a mechanical approval reflects non-application of mind and cannot be treated as valid in law. On the stated facts, the case was treated as indistinguishable, and the assessment was quashed as unsustainable. The core principle is that section 153D approval must demonstrate consideration of each individual assessment record; a group approval without that scrutiny vitiates the assessment.

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Issues: Whether the assessment framed pursuant to approval under section 153D was sustainable when the approval was granted in a consolidated manner for multiple assessees and assessment years without indicating application of mind to each individual assessment record.

Analysis: The approval sought and granted under section 153D was in respect of a group of cases covering multiple assessees and assessment years. The order noted that the coordinate Benches had already examined the same approval process and held that, where the approval order does not reflect examination of the assessment records of each assessee separately, the approval suffers from non-application of mind and cannot be treated as valid in law. The present case was found to be indistinguishable on facts.

Conclusion: The approval under section 153D was held invalid for non-application of mind, and the assessment was quashed in favour of the assessee.

Final Conclusion: The appeal succeeded and the impugned assessment could not be sustained.

Ratio Decidendi: A consolidated approval under section 153D that does not demonstrate consideration of the individual assessment record of each assessee and each assessment year is invalid for non-application of mind, rendering the assessment unsustainable.

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