Consolidated Section 153D approval invalidated - year wise independent approval required; assessment under Section 153A quashed.

Whether a consolidated approval for multiple assessment years satisfies statutory requirements under the law was examined: the approval must show independent application of mind year wise and cannot be a mechanical or summary endorsement; where the approving authority's observations were general and did not demonstrate per year consideration despite differing factual issues, the consolidated approval was held invalid and the consequent assessment framed was quashed in favour of the assessee.

---

---

Issues: Whether the consolidated approval granted under Section 153D of the Income-tax Act, 1961 for multiple assessment years is valid, or whether approval must be granted separately for each assessment year with an independent application of mind, and whether the assessment framed under Section 153A of the Income-tax Act, 1961 should be quashed for defective approval.

Analysis: The Court examined the approval letter relied upon by the Revenue and the material on record and found the approval to be a consolidated approval for multiple assessment years without any indication that the approving authority perused draft orders or applied independent mind to each assessment year separately. The Court applied the statutory scheme of Section 153A and Section 153D of the Income-tax Act, 1961 and followed precedents establishing that approval under Section 153D must reflect an appropriate application of mind in respect of each assessment year and cannot be a mere mechanical exercise or rubber stamping. The Court noted factual distinctions across assessment years in issues raised and found the approving authority's summary observations to be general and insufficient to show year-wise consideration.

Conclusion: The consolidated approval under Section 153D of the Income-tax Act, 1961 is invalid; approval must be granted for each assessment year with independent application of mind. The appeal is allowed and the assessment framed under Section 153A of the Income-tax Act, 1961 is quashed in favour of the assessee.

---