ITAT allowed the appellant's appeal, quashing assessment orders...

ITAT allowed the appellant's appeal, quashing assessment orders due to invalid approval under section 153D. The approving authority granted mechanical approval without examining draft orders or indicating thought process, merely rubber-stamping the request using statutory language. Following Orissa HC precedent in ACIT vs Serajuddin & Co., ITAT held that section 153D approval requires meaningful examination by approving authority with indication of reasoning, not mere procedural compliance. Single approval covering multiple assessment years without reference to seized materials demonstrated lack of proper application of mind. Court emphasized that mechanical approval vitiates entire assessment order, as section 153D compliance is mandatory substantive requirement, not mere procedural formality. Revenue's contention that approval is non-justiciable was rejected, establishing that courts can examine approval validity.

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