Mechanical approval under Section 148B vitiates reassessment when the authority fails to apply independent mind.

Prior approval under Section 148B is a statutory safeguard requiring the approving authority to independently examine the draft assessment order and relevant material before consent is granted. Where the approval is brief, non-speaking and does not disclose meaningful scrutiny of the proposed additions, it is mechanical and the resulting assessment is vitiated. On the facts, the Tribunal found the approval to be a rubber-stamp exercise without independent application of mind, so the assessment order was unsustainable in law and was quashed. The additional ground was allowed, and the merits of the additions were not examined as they became academic.

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Issues: Whether the assessment order under Section 143(3) of the Income-tax Act, 1961 was vitiated because the approval under Section 148B was granted mechanically and without application of mind.

Analysis: The Tribunal held that prior approval under Section 148B is a statutory safeguard and not a mere formality. The approval order must reflect that the approving authority examined the draft assessment order and the relevant material before granting consent. On the facts, the approval was found to be a brief, non-discernible exercise that did not reveal any independent consideration of the additions proposed by the Assessing Officer. The Tribunal treated the approval as mechanical and inconsistent with the legal requirement of meaningful scrutiny by the approving authority.

Conclusion: The assessment order was held unsustainable in law and was quashed. The additional ground was allowed, and the remaining grounds on the merits of the additions became academic and were not adjudicated.

Final Conclusion: The appeals were allowed because the impugned assessments failed at the threshold for want of valid approval.

Ratio Decidendi: Where the statute requires prior approval for a draft assessment, the approving authority must independently apply its mind to the relevant facts and material, and a mechanical or rubber-stamp approval vitiates the consequent assessment.

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