Independent approval under section 153D is mandatory for each assessment year; common mechanical sanction vitiates assessments.

Prior approval under section 153D must be granted separately for each assessment year and must show independent application of mind to the draft order and relevant material. A consolidated sanction for multiple years, without any indication of separate examination, is treated as mechanical compliance and fails the statutory safeguard. On that basis, the assessments founded on such common approval were quashed in favour of the assessee. The appeal succeeded on the jurisdictional objection, while the remaining grounds were not adjudicated and were left open.

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Issues: Whether the common approval granted under section 153D for multiple assessment years was valid and whether the assessment proceedings based on such approval were liable to be quashed.

Analysis: The approval was granted in a consolidated manner for several assessment years and for connected cases on the same day. The requirement under section 153D is a prior approval for each assessment year, and the approving authority must apply an independent mind to the draft assessment order and relevant material. A common or mechanical approval, without indication of examination of the records or separate consideration of each year, does not satisfy the statutory safeguard. The precedents relied upon were found to support the view that such perfunctory approval vitiates the assessment.

Conclusion: The common approval under section 153D was invalid, and the assessments founded on it were quashed in favour of the assessee.

Final Conclusion: The appeal succeeded on the jurisdictional objection, while the other grounds were not adjudicated and were left open.

Ratio Decidendi: Approval under section 153D must reflect independent application of mind to each assessment year, and a consolidated or mechanical sanction is not a valid compliance with the statutory mandate.

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