CIT v. S. Goyanka Lime & Chemical Ltd.

64 Taxmann.com 313Supreme Court of India2015#226 most cited

What is CIT v. S. Goyanka Lime & Chemical Ltd. authority for?

A mechanical approval by the prescribed authority under Section 151, made without independent application of mind, vitiates and renders the entire reassessment proceedings invalid. Such approvals, often indicated by brief, unreasoned endorsements, lead to the quashing of the reopening of assessment.

340

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. S. Goyanka Lime & Chemical Ltd. · S. Goyanka Lime & Chemical Ltd. · Section 151 · Section 147 · Section 148 · mechanical approval · non-application of mind · sanctioning authority · approval for reopening · vitiates reopening · reassessment validity · Income Tax Act 1961

Also reported as

237 Taxmann 378453 ITR 242

Issues it is cited on

Judgments citing CIT v. S. Goyanka Lime & Chemical Ltd.

Mohammad Parwaiz Akhtar, Gurgram vs. Ward 2(5) Gurgaon., Gurgaon

Appeal is allowed

ITA 7125/DEL/2025[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Sh. Satbeer Singh Godaraita No. 7125/Del/2025 : Asstt. Year: 2012-13 Mohammad Parwaiz Akhtar, Vs Income Tax Officer, D-46, Rosewood City, Sector-49, Ward-2(5), Gurgaon-122001 Gurgaon-122001 (Appellant) (Respondent) Pan No. Ajvpa8534D Assessee By: Sh. Shikhar Garg, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 29.01.2026 Date Of Pronouncement: 29.01.2026 Order This Assessee’S Appeal For Assessment Year 2012-13 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1064352870(1) Dated 25.04.2024, In Proceedings U/S 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Shikhar Garg, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(3)Section 151

…ed authority had accepted the Assessing Officer’s reopening proposal as “I am 2 Mohammad Parwaiz Akhtar satisfied.........”. This being the clinching factual position emanating from the record, we hereby quote CIT vs. S. Goyanka Lime and Chemical Ltd. (2023) 453 ITR 242 (SC) that such a mechanical approval vitiates the entire reopening; and therefore, I accept the instant legal ground in very terms. This reopening is quashed therefore. 4. All other pleadings on merits stand rendered academic. 5. This assessee’s appeal is allowed. Order Pronounced in the Open Court on 29/01/2026. (Satbeer Singh Godara) Judicia…

Shokinder Kumar, Uttar Pradesh vs. ITO Ward - 2 (3), Ghaziabad

Appeal is allowed

ITA 9011/DEL/2025[2011-12]Status: DisposedITAT Delhi22 Jan 2026AY 2011-12

Bench: Sh. Satbeer Singh Godaraita No. 9011/Del/2025 : Asstt. Year: 2011-12 Shokinder Kumar, Vs Income Tax Officer, S/O Sh. Chaman Singh, Ward-2(3), C-183, Mahenderpuri, Modi Nagar, Ghaziabad-201002 Ghaziabad-201204 (Appellant) (Respondent) Pan No. Dqtpk9105E Assessee By: Sh. Sahil Sharma, Adv. & Sh. Sanjay Prashar, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 22.01.2026 Order This Assessee’S Appeal For Assessment Year 2011-12 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1071012801(1) Dated 09.12.2024, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Sahil Sharma, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 151

…ribed authority had accepted the Assessing 2 Shokinder Kumar Officer’s reopening proposal as “Yes, I am satisfied.........”. This being the clinching factual position emanating from the record, we hereby quote CIT vs. S. Goyanka Lime and Chemical Ltd. (2023) 453 ITR 242 (SC) that such a mechanical approval vitiates the entire reopening; and therefore, I accept the instant legal ground in very terms. This reopening is quashed therefore. 4. All other pleadings on merits stand rendered academic. 5. This assessee’s appeal is allowed. Order Pronounced in the Open Court on 22/01/2026. (Satbeer Singh Godara) Judicia…

Mahendar Kumar Soni, Delhi vs. Income Tax Officer, Ward 34(2), New Delhi

Appeal is allowed

ITA 6507/DEL/2025[2012-13]Status: DisposedITAT Delhi22 Jan 2026AY 2012-13

Bench: Sh. Satbeer Singh Godaraita No. 6507/Del/2025 : Asstt. Year: 2012-13 Mahendar Kumar Soni, Vs Income Tax Officer, Ag-366, Shalimar Bagh, Ward-34(2), Delhi-110088 New Delhi-110002 (Appellant) (Respondent) Pan No. Anhps4082N Assessee By: Sh. Sumit Lalchandani, Adv. & Ms. Sakshi Rustagi, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 22.01.2026 Order This Assessee’S Appeal For Assessment Year 2012-13 Arises Against The Cit(A)-25, New Delhi’S Din & Order No. Itba/Apl/M/250/2025-26/1079333080(1) Dated 06.08.2025, In Proceedings U/S 143(3)/147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Sumit Lalchandani, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 143(3)Section 151

…scribed authority had accepted the Assessing Officer’s reopening proposal as “I am satisfied.........”. This 2 Mahendar Kumar Soni being the clinching factual position emanating from the record, we hereby quote CIT vs. S. Goyanka Lime and Chemical Ltd. (2023) 453 ITR 242 (SC) that such a mechanical approval vitiates the entire reopening; and therefore, I accept the instant legal ground in very terms. This reopening is quashed therefore. 4. All other pleadings on merits stand rendered academic. 5. This assessee’s appeal is allowed. Order Pronounced in the Open Court on 22/01/2026. (Satbeer Singh Godara) Judicia…

Rajesh Gupta, Delhi vs. ITO, Uttar Pradesh

Appeal is allowed

ITA 7432/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 7432/Del/2025 : Asstt. Year: 2017-18 Rajesh Gupta (Individual), Vs Income Tax Officer, Sahni Natarajan & Bahl, Ward-2(3)(4), Chartered Accountatns, 303, Hapur, Mansarovar, 90, Nehru Place, Uttar Pradesh-245101 New Delhi-110019 (Appellant) (Respondent) Pan No. Agopg1144M Assessee By: Sh. Sumit Lalchandani, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081279200(1) Dated 29.09.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Sumit Lalchandani, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 151

…thority had accepted the Assessing 2 Rajesh Gupta Officer’s reopening proposal as “Yes, in view of the reasons............”. This being the clinching factual position emanating from the record, we hereby quote CIT vs. S. Goyanka Lime and Chemical Ltd. (2023) 453 ITR 242 (SC) that such a mechanical approval vitiates the entire reopening; and therefore, I accept the instant legal ground in very terms. This reopening is quashed therefore. 4. All other pleadings on merits stand rendered academic. 5. This assessee’s appeal is allowed. Order Pronounced in the Open Court on 20/01/2026. (Satbeer Singh Godara) Judicia…

Arihant Chand Jain, Delhi vs. DCIT, Circle-59(1), Delhi

Appeal is allowed

ITA 5330/DEL/2025[2009-10]Status: DisposedITAT Delhi20 Jan 2026AY 2009-10

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5330/Del/2025 : Asstt. Year : 2009-10 Arihant Chand Jain, Vs Dcit, Parganj Industrial Area, Circle-59(1), New Delhi-110092 New Delhi-110092 (Appellant) (Respondent) Pan No. Aafpj4556K Assessee By : Sh. Neeraj Mangla, Ca Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2009-10, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024–25/1065412541(1) Dated 05.06.2024, In Proceedings U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Neeraj Mangla, CAFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 147Section 151

…ook) wherein the learned prescribed authority had accepted the Assessing Officer’s reopening proposal as “I am satisfied………”. This being the clinching factual position emanating from the record, we hereby quote CIT vs. S. Goyanka Lime and Chemical Ltd. (2023) 453 ITR 242 (SC) that such a mechanical approval vitiates the entire reopening; and therefore, we accept the instant legal ground in very terms. This reopening is quashed therefore. 5. All other pleadings on merits stand rendered academic. 6. This assessee’s appeal is allowed. Order Pronounced in the Open Court on 20/01/2026. (Amitabh Shukla) (Satbeer Sin…

Rakesh Divedi, Delhi vs. Income Tax Officer, Ward 43(6), Delhi

In the result, appeal of the Assessee is allowed

ITA 3290/DEL/2025[2009-10]Status: DisposedITAT Delhi09 Jan 2026AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwalrakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. Pan-Apcpd9179A (Appellant) (Respondent) Shri Pranshu Singhal, Ca Assessee By & Ms. Mansi Jain, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 09/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 07.03.2025 In Appeal No.40/10204/2018-19 Arising Out Of The Order Passed By The Income Tax Officer, Ward-40(3) U/S 143(3) Of The Act (‘The Act’ For Short) Dated 20.12.2016 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Proprietor Of M/S Triambkay Gauri Impex. The Information Was Received By The Ao From Investigation Wing That There Were Cash Deposits In The Bank Account Of The Assesse With Icici Bank, However, Income Of The Assessee & Gross Receipt Has Not Rakesh Divedi Vs. Income Tax Officer Commensurate With The Cash So Deposited, Therefore, After Recording The Reason U/S 147, Notice U/S 148 Was Issued On 31.03.2016 After Obtaining Statutory Approval From The Pcit. Thereafter, Assessment Was Completed Vide Order Dated 20.12.2016 Wherein Total Addition Of Rs. 5,20,88,345/- Was Made U/S 68 Of The Act For Cash Deposited In The Bank Accounts By Holding The Same As Unexplained Cash Credits. 3. Against The Said Order, Assessee Has Filed An Appeal Before Ld. Cit(A) Who Vide Impugned Order Has Partly Allowed The Appeal Of The Assessee & Directed The Ao To Make Addition Of Peak Credit Of The Total Deposits In The Bank Accounts.

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Rakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. PAN-APCPD9179A (Appellant) (Respondent) Shri Pranshu Singhal, CA Assessee by and Ms. Mansi Jain, Adv. Department by Ms. Ankush Kalra, Sr. DR Date of Hearing 30/10/2025 Date of Pronouncement 09/01/2026 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the Assessee against the order of the Learned Commissioner of Income Tax (Appeals), National Fa…