Mechanical Rubber-Stamp Approval under Section 153D Vitiates Entire Search Assessment: Bombay HC

The Bombay High Court held that sanction granted under Section 153D of the Income Tax Act must reflect mindful, independent application of mind, and cannot be a mechanical rubber-stamp. The case involved search-based assessments where the Joint Commissioner approved numerous assessment orders in a single day without examining case-specific material. The Court ruled that such mechanical approval violates statutory safeguards meant to protect taxpayers from arbitrary assessments. Consequently, the entire assessment was quashed. The judgment reinforces the mandatory nature of Section 153D, holding that higher-level approval is not a mere formality but a substantive requirement ensuring due process. It serves as a precedent for taxpayers challenging search-related assessments where approvals appear hurried, generic, or non-reasoned, and signals strict judicial scrutiny of tax-administrative practices.