Section 153D approval must be assessment-specific; a common omnibus approval could not sustain the assessments.

Assessments framed under section 143(3) read with section 153A were challenged on the ground that approval under section 153D was not validly granted. The assessee was allowed to raise this legal ground in appeal because it went to the root of the matter and the relevant facts were already on record. The assessment records showed that one common approval had been sought and granted for multiple assessment years. Applying the principle that section 153D approval must be specific and valid for each assessment, the omnibus combined approval was treated as invalid and the assessments were quashed in favour of the assessee.

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Issues: Whether the assessments framed under section 143(3) read with section 153A were vitiated for want of valid approval under section 153D, where a common approval was granted for multiple assessment years.

Analysis: The assessee was permitted to raise the additional legal ground in appellate proceedings because it went to the root of the matter and the relevant facts were already on record. The assessment records showed that the Assessing Officer sought one common approval for all the assessment years covered by the batch, and the prescribed authority granted that combined approval. On the settled principle that approval under section 153D must be specific and valid for each assessment, a common omnibus approval for several years could not sustain the assessments.

Conclusion: The combined approval under section 153D was held invalid and the impugned assessments were quashed, in favour of the assessee.

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