Mechanical approval under section 148B invalidated reassessment proceedings and led to quashing of the assessments.

Approval granted under section 148B was treated as mechanical because a single combined approval covered six assessees, including the present assessees, without proper application of mind. Following a coordinate Bench view on identical facts, such approval was held not sustainable, with the result that the reassessment proceedings and consequential assessments for AYs 2021-22 and 2022-23 were quashed.

---

---

Issues: Whether the approval granted under section 148B of the Income-tax Act, 1961 was mechanical and application of mind, rendering the reassessment proceedings and consequent assessments unsustainable.

Analysis: The approval dated 23.05.2023 was found to be a combined approval covering six assessees, including the present assessees, and was held to be mechanical and without application of mind. The reasoning adopted in a coordinate Bench decision on identical facts was followed, where such combined approval had been treated as not sustainable and the assessments had been quashed on the ground of invalid approval.

Conclusion: The approval under section 148B was invalid, and the assessments for AYs 2021-22 and 2022-23 were quashed. The appeals were allowed in favour of the assessees.

---