Mechanical approval under section 153D vitiates assessment where the approving authority fails to apply independent mind.

Prior approval under section 153D must show independent application of mind to the draft assessment order; a mechanical or perfunctory approval has no legal sanctity. Where the approving authority merely rubber-stamps the proposal without meaningful examination of the material or year-wise requirements, the defect goes to the root of the proceedings and vitiates the assessment framed under section 153A. On that basis, the assessment proceedings were held invalid and the assessment orders were quashed.

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Issues: Whether the assessment proceedings were liable to be quashed for want of valid prior approval under section 153D of the Income-tax Act, 1961, on the ground that the approval was mechanical and without application of mind.

Analysis: The approval granted under section 153D must reflect independent consideration of the draft assessment order and cannot be a mere ritualistic or rubber-stamping exercise. Where the approving authority grants approval in a perfunctory manner, without meaningful examination of the material or the assessment year-wise requirements, the approval lacks legal sanctity. In such circumstances, the defect goes to the root of the proceedings and vitiates the consequent assessment framed under section 153A.

Conclusion: The assessment proceedings were held invalid for want of a proper approval under section 153D, and the assessment orders were quashed.

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