Section 153D approval must be year-specific and reasoned; omnibus mechanical sanction vitiates section 153A assessments.

Assessments framed under section 153A were invalid because the approving authority did not grant a separate, reasoned approval under section 153D for each assessment year. A common approval covering multiple years, without discernible consideration of the draft orders, seized material, or year-wise additions, was treated as omnibus and mechanical. That non-application of mind breached the statutory safeguard in section 153D and vitiated the assessments. The appeals were allowed and the assessments quashed.

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Issues: Whether the assessments framed under section 153A were vitiated for want of valid approval under section 153D, where a common approval was granted for multiple assessment years without separate application of mind to each year.

Analysis: The approval under section 153D was required to be granted independently for each assessment year and on consideration of the material relevant to that year. The common approval letter covered several years together and did not show any discernible examination of the draft assessment orders, seized material, or the issues proposed for addition in each year. The approval was therefore found to be omnibus and mechanical rather than the result of an independent judicial or administrative appraisal. On the binding precedents relied upon, such non-application of mind defeats the statutory safeguard built into section 153D and vitiates the assessments framed on that basis.

Conclusion: The assessments were held invalid and quashed for want of proper approval under section 153D, and the assessee's appeals were allowed.

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