Pursuant to a search and seizure under section 132 the Assessing Officer passed an order. On appeal the Tribunal found that the draft assessment orders under section 153D were placed for approval on December 31, 2017 and that the Additional Commissioner on the same day had granted approval under section 153D in the cases of 123 assessees which included the three cases of the assessee. The Tribunal held that it was humanly impossible for the approving authority to peruse the material based on which the draft assessment orders were passed and that therefore, the approving authority had granted approval under section 153D in a mechanical manner which vitiated the entire proceedings. On appeal dismissing the appeal, that the draft assessment orders under section 153A in the cases of 123 assessees placed before the approving authority on December 30, 2017 and December 31, 2017 were approved under section 153D on December 31, 2017, which not only included the cases of the assessee but the cases of other groups as well. It was humanly impossible to go through the records of 123 cases in one day to apply independent mind to appraise the material before the approving authority. The conclusion drawn by the Tribunal that it was a mechanical exercise of power by the approving authority was not perverse or contrary to the material on record. No question of law arose. (AY. 2013-14, 2015-16, 2016-17)