Section 153D approval must be separate and reasoned for each assessment year; consolidated approval invalidates the assessment.

Section 153D requires prior approval for each assessment year after application of mind to the draft search assessment order. A consolidated or blanket approval covering multiple assessees and assessment years in one exercise does not meet that statutory requirement and is treated as mechanical. On that basis, the assessment was held unsustainable and was quashed, with the additional ground allowed.

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Issues: Whether the assessment was vitiated because approval under section 153D was granted in a consolidated and mechanical manner for multiple assessees and assessment years.

Analysis: The approval for the draft search assessment orders was accorded in one consolidated exercise covering several assessees and assessment years together. Section 153D requires prior approval after application of mind for each assessment year separately. A combined or blanket approval does not satisfy the statutory requirement and renders the assessment unsustainable.

Conclusion: The consolidated approval under section 153D was invalid, the assessment was quashed, and the additional ground was allowed.

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