Mechanical Approval Invalid

The Delhi Bench of the Income Tax Appellate Tribunal in Periwal Polymers Pvt. Ltd. v. DCIT held that approval granted under Section 153D must reflect an independent application of mind by the approving authority. The Tribunal found that the Additional Commissioner had issued a consolidated approval covering multiple assessment years, which indicated a mechanical exercise of power. Referring to binding precedents of the Delhi High Court, the Tribunal observed that approval under Section 153D must be granted year-wise after proper examination of the draft assessment orders and material on record. Since this statutory requirement was not satisfied, the Tribunal held that the assessments framed under Section 153C read with Section 143(3) were legally unsustainable and therefore liable to be quashed.