Section 153D approval must be year-specific; a consolidated mechanical sanction can vitiate search-related assessments.

A consolidated approval under section 153D for multiple assessment years was treated as legally insufficient where it did not show independent examination of each draft assessment year-wise. The Tribunal stated that meaningful approval requires application of mind to the relevant material for each year separately, and a mechanical common sanction does not satisfy the statutory safeguard. On that basis, the defect was held to go to the root of the assessments framed under section 153C, rendering them unsustainable and leading to annulment of the assessments.

---

---

Issues: Whether a common approval granted under section 153D for multiple assessment years, without independent consideration for each year, vitiates assessments framed under section 153C.

Analysis: The assessments were framed pursuant to search proceedings, but the decisive challenge was to the approval process under section 153D. The approval granted by the prescribed authority covered several assessment years in one consolidated communication. The Tribunal held that such a combined approval, lacking any indication of independent examination of the draft assessments and reflecting no application of mind to each year separately, does not satisfy the statutory requirement of meaningful approval. On that basis, the Tribunal followed the cited authorities to hold that the defect went to the root of the assessments and rendered them unsustainable.

Conclusion: The common section 153D approval was invalid and the assessments for the years in appeal were quashed in favour of the assessee.

Ratio Decidendi: A section 153D approval must show independent application of mind to the draft assessment for each relevant year, and a consolidated mechanical approval for multiple assessment years is not a valid sanction and vitiates the assessment.

---