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“mechanical approval”

ReassessmentSection 151Section 1511,395 judgments

The decision most relied on for mechanical approval is PCIT v. Shiv Kumar Nayyar (163 Taxmann.com 9), cited in 597 judgments on BharatTax.

Leading authorities on mechanical approval

PCIT v. Shiv Kumar Nayyar
163 Taxmann.com 9 · 2024 · High Court
597
citing judgments

Approval under Section 153D for search assessments is invalid if granted mechanically, hastily, or without due application of mind, such as on the same day as the proposal or in a bunched manner. Such an invalid approval renders the consequential assessment order under Section 153A void ab initio.

CIT v. S. Goyanka Lime & Chemical Ltd.
64 Taxmann.com 313 · 2015 · Supreme Court
340
citing judgments

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.

ACIT v. Sirajuddin& Co.
150 Taxmann.com 146 · 2023 · High Court
288
citing judgments

Assessment orders are bad in law if they are passed without valid approval from the Additional Commissioner under Section 153D, or if such approval is granted mechanically without application of mind.

Shreelekha Damani v. DCIT
173 TTJ 332 · 2015 · ITAT
236
citing judgments

Approval granted by a superior authority under Section 153D in a mechanical or perfunctory manner, without proper application of mind, lacks legal sanctity and renders the subsequent assessment order null and void.

Principal Commissioner of Income-tax v. Subodh Agarwal
149 Taxmann.com 373 · 2023 · High Court
194
citing judgments

Approval of draft assessment orders under Section 153D must be granted with due application of mind, not mechanically. Approving multiple cases, such as 38 in a single day, without proper scrutiny amounts to mechanical approval, rendering the assessment invalid.

Madhya Pradesh in CIT v. S. Goyanka Lime & Chemicals Ltd.
56 Taxmann.com 390 · 2015 · High Court
188
citing judgments

A sanction for issuing a notice under section 148 is invalid if the sanctioning authority grants approval mechanically, merely recording 'Yes, I am satisfied' without proper application of mind to the reasons for reassessment. The authority must demonstrate proper consideration to fulfill the statutory obligation under section 151.

PCIT v. Anuj Bansal
165 Taxmann.com 2 · 2024 · High Court
181
citing judgments

An approval under Section 153D of the Income Tax Act, 1961, is considered mechanical and invalid if granted without application of mind and without perusing relevant assessment records, including seized material. This principle has been affirmed by multiple High Courts and the Supreme Court.

CIT v. SPL’s Siddhartha Ltd.
345 ITR 223 · 2012 · High Court
164
citing judgments

Reassessment proceedings under Section 147 are invalid if the sanction required under Section 151 is obtained mechanically, without independent application of mind by the sanctioning authority, or is based on borrowed satisfaction.

Judgments citing mechanical approval

Govind Sharma, Mathura vs. ITO, Ward 1(3)(1), Mathura

In the result, the assessee’s appeal is allowed

ITA 428/AGR/2025[2015-16]Status: DisposedITAT Agra17 Apr 2026AY 2015-16
Section 10(38)Section 147Section 148Section 151Section 250Section 68

raised by the appellant assessee, challenging the validity of assumption of jurisdiction u/s. 147 of the Act by the ld A.O. being passed on mechanical approval u/s. 151 of the Act, goes to the root of the matter. We deem it fit to address the same first. The additional ground ... been granted absolutely in a casual and mechanical manner without application of mind. Ld AR, thus submits that the assessment proceedings based on such mechanical approval not recognized under law vitiates. Ld AR has referred order dated 26.11.2025 passed in ITA No. 386/Agr/2025 for A.Y. 2020-21 and order dated

DCIT, Central Circle-14, New Delhi, Jhandewalan Extn vs. Shyam Sunder Verma, Model Town-III

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 8072/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumardcit Vs. Shyam Sunder Verma Central Circle 14 R-66/2, Model Town-Iii New Delhi North West Delhi 110009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acbpv 9328 D Appellant .. Respondent

For Appellant: Sh. Sandeep Goel, AdvFor Respondent: Ms. Monika Singh, CIT-DR
Section 127Section 132Section 142(1)Section 143(2)Section 143(3)Section 153BSection 153CSection 153DSection 250

that impugned assessment order passed u/s 143(3) of 1961 Act is invalid as assessment order is passed without as based upon invalid and mechanical approval u/s 153D given in combined and consolidated manner without giving any independent reasoning qua each year in the approval memo. 2 Without prejudice ... jurisdictional ground relating to validity of instant reopening u/s 147/148 was duly raised and pleaded before Ld. CIT(A) and jurisdictional aspect of mechanical approval u/s 151 of Addl CIT qua impugned assessment framed P a g e | 5 Shyam Sunder Verma (AY 2017-18) u/s 143(3)/147

Itahar Consumers Cooperative Stores Limited, Itahar vs. ITO, Karnajora

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1593/KOL/2025[2018-19]Status: DisposedITAT Kolkata08 Apr 2026AY 2018-19

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115BSection 144Section 147Section 148ASection 250Section 69A

violation of principles of natural justice. 5. That the initiation and completion of proceedings under section 147 r.w.s. 144B without proper opportunity and mechanical approval is invalid and liable to be quashed. 6. That the addition u/s 69A and invoking of section 115BBE without any incriminating material or valid reason

Kundan Jewellers Private Limited, Gandhi Chowk, Sadar Bazar, Muktsar vs. The Income Tax Officer, Ward-2(2), Muktsar

In the result, the appeal of the assessee is allowed

ITA 284/ASR/2025[2014-15]Status: DisposedITAT Amritsar06 Apr 2026AY 2014-15

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. Sudhir Sehgal, A. R
Section 147Section 148Section 153CSection 250Section 69A

wrong facts which are contradictory to the addition made by the AO in the assessment order. (iii) That there was mechanical approval of the Pr. CIT with regard to reopening of the case u/s 148 of the Act. 3. That the Ld. CIT(A) NFAC, vide order

Kashyap Kaniyalal Mehta, Mumbai vs. DCIT CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 6203/MUM/2024[2018-19]Status: DisposedITAT Mumbai27 Mar 2026AY 2018-19
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 153ASection 68Section 69C

joint warrant in searches. Secondly, no mandatory DIN on the body of the assessment orders. 27 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Thirdly, incompetent and mechanical approval u/s153Dof the Act by the Addl CIT. Lastly, illegal jurisdiction of the AO based on a void ab initio assessment jurisdictional order passed

Kashyap Kaniyalal Mehta, Mumbai vs. DCIT CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 6202/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Mar 2026AY 2017-18
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 153ASection 68Section 69C

joint warrant in searches. Secondly, no mandatory DIN on the body of the assessment orders. 27 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Thirdly, incompetent and mechanical approval u/s153Dof the Act by the Addl CIT. Lastly, illegal jurisdiction of the AO based on a void ab initio assessment jurisdictional order passed

Kashyap Kaniyalal Mehta, Mumbai vs. DCIT CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 6201/MUM/2024[2016-17]Status: DisposedITAT Mumbai27 Mar 2026AY 2016-17
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 153ASection 68Section 69C

joint warrant in searches. Secondly, no mandatory DIN on the body of the assessment orders. 27 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Thirdly, incompetent and mechanical approval u/s153Dof the Act by the Addl CIT. Lastly, illegal jurisdiction of the AO based on a void ab initio assessment jurisdictional order passed

Kashyap Kaniyalal Mehta, Mumbai vs. DCIT CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 6200/MUM/2024[2015-16]Status: DisposedITAT Mumbai27 Mar 2026AY 2015-16
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 153ASection 68Section 69C

joint warrant in searches. Secondly, no mandatory DIN on the body of the assessment orders. 27 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Thirdly, incompetent and mechanical approval u/s153Dof the Act by the Addl CIT. Lastly, illegal jurisdiction of the AO based on a void ab initio assessment jurisdictional order passed

Kashyap Kaniyalal Mehta, Mumbai vs. DCIT CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 6199/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Mar 2026AY 2014-15
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 153ASection 68Section 69C

joint warrant in searches. Secondly, no mandatory DIN on the body of the assessment orders. 27 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Thirdly, incompetent and mechanical approval u/s153Dof the Act by the Addl CIT. Lastly, illegal jurisdiction of the AO based on a void ab initio assessment jurisdictional order passed

Kashyap Kaniyalal Mehta, Mumbai vs. DCIT CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 6198/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Mar 2026AY 2012-13
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 153ASection 68Section 69C

joint warrant in searches. Secondly, no mandatory DIN on the body of the assessment orders. 27 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Thirdly, incompetent and mechanical approval u/s153Dof the Act by the Addl CIT. Lastly, illegal jurisdiction of the AO based on a void ab initio assessment jurisdictional order passed

Kashyap Kaniyalal Mehta, Mumbai vs. DCIT, CC-4(1), Mumbai

In the result, appeals of the assessee are allowed

ITA 6197/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Mar 2026AY 2011-12
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 153ASection 68Section 69C

joint warrant in searches. Secondly, no mandatory DIN on the body of the assessment orders. 27 ITA No.6197-6203/Mum/2024 Kashyap Kaniyalal Mehta Thirdly, incompetent and mechanical approval u/s153Dof the Act by the Addl CIT. Lastly, illegal jurisdiction of the AO based on a void ab initio assessment jurisdictional order passed

DCIT, Central Circle-28, New Delhi vs. Manoj Kumar Singh, New Delhi

In the result, appeal filed by the assessee is allowed and the appeal of the

ITA 30/DEL/2026[2014-15]Status: DisposedITAT Delhi27 Mar 2026AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumarmanoj Kumar Singh Vs. Dcit, S-17, Ground Floor, Central Circle-28 Panchsheel Enclave, New Delhi New Delhi – 110 017 Pan: Aaxps2824H (Appellant) (Respondent) Dcit, Vs. Manoj Kumar Singh Central Circle-28 S-17, Ground Floor, New Delhi Panchsheel Enclave, New Delhi- 110 017 Pan: Aaxps2824H (Appellant) (Respondent)

Section 143(3)Section 153ASection 153D

requirement of Section 153D of the Act. As for convenience the relevant grounds raised in the appeal of assessee is reproduced as under: “Re: Mechanical approval under section 153D of the Act. 1. Because Ld. CIT(A) has erred in law and on the facts in confirming the Assessment Order ... without appreciating that the draft Assessment Order was mechanically approved by jurisdictional JCIT-Range 8, Delhi (now Range- 7), without application of mind, and in complete violation of mandatory requirement of Section 153D of the Act. 1.1. Because the Hon'ble ITAT, in appellant’s own case

Manoj Kumar Singh, Delhi vs. DCIT Central Circle-28, Delhi

In the result, appeal filed by the assessee is allowed and the appeal of the

ITA 7064/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Mar 2026AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumarmanoj Kumar Singh Vs. Dcit, S-17, Ground Floor, Central Circle-28 Panchsheel Enclave, New Delhi New Delhi – 110 017 Pan: Aaxps2824H (Appellant) (Respondent) Dcit, Vs. Manoj Kumar Singh Central Circle-28 S-17, Ground Floor, New Delhi Panchsheel Enclave, New Delhi- 110 017 Pan: Aaxps2824H (Appellant) (Respondent)

Section 143(3)Section 153ASection 153D

requirement of Section 153D of the Act. As for convenience the relevant grounds raised in the appeal of assessee is reproduced as under: “Re: Mechanical approval under section 153D of the Act. 1. Because Ld. CIT(A) has erred in law and on the facts in confirming the Assessment Order ... without appreciating that the draft Assessment Order was mechanically approved by jurisdictional JCIT-Range 8, Delhi (now Range- 7), without application of mind, and in complete violation of mandatory requirement of Section 153D of the Act. 1.1. Because the Hon'ble ITAT, in appellant’s own case

Rajeev Aggarwal, Faridabad Haryana vs. Deputy Commissioner of Income Tax Central Circle 1 Faridabad, Faridabad Haryana

In the result, the appeal of the assessee is allowed

ITA 1397/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Mar 2026AY 2019-20

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

Section 132Section 132(1)Section 153D

assessee submitted that in the present case, approval was granted by Ld. Addl. CIT, Central Range, Gurugram, vide letter dated 17.08.2021 which is mechanical approval. Ld. Counsel for the assessee further submits that Ld. Addl. CIT granted approval ... submits that from the perusal of the same it could be seen that the approval granted by the ld. Addl. CIT was mechanical approval as no separate approval for each Assessment Year was given rather approval was given by a single order for various assessment years. The approvals so granted

Abvpa5814C, Faridabad Haryana vs. Deputy Commissioner of Income Tax Central Circle -1 Faridabad, Faridabad Haryana

In the result, the appeal of the assessee is allowed

ITA 1381/DEL/2025[2018-19]Status: DisposedITAT Delhi27 Mar 2026AY 2018-19

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

Section 132Section 132(1)Section 153D

assessee submitted that in the present case, approval was granted by Ld. Addl. CIT, Central Range, Gurugram, vide letter dated 17.08.2021 which is mechanical approval. Ld. Counsel for the assessee further submits that Ld. Addl. CIT granted approval ... submits that from the perusal of the same it could be seen that the approval granted by the ld. Addl. CIT was mechanical approval as no separate approval for each Assessment Year was given rather approval was given by a single order for various assessment years. The approvals so granted

Rajeev Aggarwal, Faridabad Haryana vs. Depty Commissioner of Incometax Central Circle 1 Faridabad, Faridabad Haryana

In the result, the appeal of the assessee is allowed

ITA 1380/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Mar 2026AY 2019-20

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

Section 132Section 132(1)Section 153D

assessee submitted that in the present case, approval was granted by Ld. Addl. CIT, Central Range, Gurugram, vide letter dated 17.08.2021 which is mechanical approval. Ld. Counsel for the assessee further submits that Ld. Addl. CIT granted approval ... submits that from the perusal of the same it could be seen that the approval granted by the ld. Addl. CIT was mechanical approval as no separate approval for each Assessment Year was given rather approval was given by a single order for various assessment years. The approvals so granted

Rajeev Aggarwal, Faridabad Haryana vs. Deputy Commissioner of Income Tax Central Circle 1 Faridabad, Faridabad Haryana

In the result, the appeal of the assessee is allowed

ITA 1376/DEL/2025[2017-18]Status: DisposedITAT Delhi27 Mar 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

Section 132Section 132(1)Section 153D

assessee submitted that in the present case, approval was granted by Ld. Addl. CIT, Central Range, Gurugram, vide letter dated 17.08.2021 which is mechanical approval. Ld. Counsel for the assessee further submits that Ld. Addl. CIT granted approval ... submits that from the perusal of the same it could be seen that the approval granted by the ld. Addl. CIT was mechanical approval as no separate approval for each Assessment Year was given rather approval was given by a single order for various assessment years. The approvals so granted

Rajeev Aggarwal, Faridabad Haryana vs. Deputy Commissioner of Income Tax, Faridabad Haryana

In the result, the appeal of the assessee is allowed

ITA 1370/DEL/2025[2016-17]Status: DisposedITAT Delhi27 Mar 2026AY 2016-17

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

Section 132Section 132(1)Section 153D

assessee submitted that in the present case, approval was granted by Ld. Addl. CIT, Central Range, Gurugram, vide letter dated 17.08.2021 which is mechanical approval. Ld. Counsel for the assessee further submits that Ld. Addl. CIT granted approval ... submits that from the perusal of the same it could be seen that the approval granted by the ld. Addl. CIT was mechanical approval as no separate approval for each Assessment Year was given rather approval was given by a single order for various assessment years. The approvals so granted

Rajeev Aggarwal, Faridabad Haryana vs. Deputy Commissioner of Income Tax, Faridabad Haryana

In the result, the appeal of the assessee is allowed

ITA 1369/DEL/2025[2015-16]Status: DisposedITAT Delhi27 Mar 2026AY 2015-16

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

Section 132Section 132(1)Section 153D

assessee submitted that in the present case, approval was granted by Ld. Addl. CIT, Central Range, Gurugram, vide letter dated 17.08.2021 which is mechanical approval. Ld. Counsel for the assessee further submits that Ld. Addl. CIT granted approval ... submits that from the perusal of the same it could be seen that the approval granted by the ld. Addl. CIT was mechanical approval as no separate approval for each Assessment Year was given rather approval was given by a single order for various assessment years. The approvals so granted

Vipul Agrawal, Ghaziabad, Uttar Pradesh vs. ACIT, Ghaziabad, Uttar Pradesh

In the result, the appeal of the assessee is allowed

ITA 5066/DEL/2024[2012-13]Status: DisposedITAT Delhi27 Mar 2026AY 2012-13

Bench: Shri M. Balaganesh & Shri Sudhir Kumarvipul Agrawal, Vs. Acit, 35, Chandrapuri, Hapur Chungi, Up Hapur, Road, Up (Appellant) (Respondent) Pan: Abqpa6874P

For Appellant: Shri Manoj Kumar, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 133(6)Section 143(3)Section 147Section 148Section 148ASection 151

granting approval in terms of section 151 of the Act. This approval was held by the Hon’ble Jurisdictional High court to be a mechanical approval. The relevant observation of the Hon’ble Jurisdictional High Court in this regard are reproduced herein:- “11. Section 151 of the Act clearly stipulates