Section 153D approval must reflect independent mind; mechanical omnibus sanction cannot sustain consequential assessments.

A common approval under section 153D must show independent application of mind to each draft assessment order; a mechanical omnibus sanction is invalid. Where the approving authority gives a blanket approval for multiple assessment years without indicating consideration of the draft orders, the approval cannot sustain consequential assessments under section 153C. The connected assessments were therefore quashed and the impugned assessments did not survive.

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Issues: Whether a common approval granted under section 153D for multiple assessment years, without indicating independent consideration of the draft assessment orders, was valid and whether such approval vitiated the assessments framed under section 153C.

Analysis: The common approval was found to be a mere omnibus sanction for all the assessment years, with no indication that the approving authority had examined the draft orders or applied an independent mind to each assessment. The decision relied on the settled principle that approval under section 153D cannot be a mechanical rubber-stamp exercise and must reflect some consideration of the draft orders. In the absence of such indication, the approval was treated as invalid and incapable of sustaining the assessments.

Conclusion: The combined section 153D approval was held invalid and the assessments framed under section 153C were quashed.

Final Conclusion: All the connected appeals succeeded and the impugned assessments for the relevant assessment years did not survive.

Ratio Decidendi: An approval under section 153D of the Income-tax Act, 1961 must reflect independent application of mind to the draft assessment orders for the relevant year or years, and a mechanical common approval vitiates the consequential assessment.

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