Section 153D approval requires real application of mind; mechanical sanction vitiates the search assessment.

Prior approval under section 153D is a substantive safeguard for search assessments and must be granted only after the superior authority applies its mind to the draft assessment order and relevant material. A bare or omnibus approval, without showing examination of the proposed additions or the draft order, is mechanical and does not satisfy the statutory requirement. On the facts, the approval letter did not indicate such consideration, so the approval was invalid and the assessment framed on that basis was quashed.

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Issues: Whether the approval granted under section 153D for the search assessment was valid, and whether absence of approval to the draft assessment order vitiated the assessment.

Analysis: Section 153D requires prior approval by the specified superior authority before completion of the assessment. The approval must show that the authority had before it the draft assessment order and the relevant material, and that the approval was granted after application of mind. A bare or omnibus approval, without reference to the draft order or the proposed additions, is mechanical and does not satisfy the statutory safeguard. On the facts, the approval letter did not show that the draft assessment order was examined, and the approval process did not conform to the mandated procedure.

Conclusion: The approval under section 153D was invalid and the assessment framed on that basis was quashed.

Ratio Decidendi: Prior approval under section 153D is a substantive safeguard requiring conscious consideration of the draft assessment order and relevant material; a mechanical or rubber-stamp approval vitiates the assessment.

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