← All Phrases

“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

An approval under Section 153D of the Income Tax Act must demonstrate that the approving authority applied its mind to the draft assessment order, and a perfunctory or mechanical approval invalidates subsequent adjustments.

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.

Vijayadevi Naval Kishore Bharatia v. Land Acquisition Officer
5 SCC 83 · 2003 · Supreme Court
167
citing judgments

Statutory approvals required under the Income Tax Act, particularly for assessments, must reflect a genuine application of mind by the approving authority and cannot be mechanical or granted without due consideration.

Judgments citing mechanical approval

Ankur Chaudhary, Noida vs. DCIT, Central Circle-1, Noida

ITA 2120/DEL/2023[2016-17]Status: DisposedITAT Delhi29 Sept 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

significantly distinguishable from the fact all those cases where Hon’ble Courts and Hon’ble Tribunal have held approval under section 153D as a mechanical approval without due application of mind by the approving authority. Moreover, content of the approval letter clearly establishes that while granting approval, the ITAs

DCIT, Central Circle-1, Noida vs. Braj Pal Singh, Noida

ITA 2386/DEL/2022[2015-16]Status: DisposedITAT Delhi29 Sept 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

significantly distinguishable from the fact all those cases where Hon’ble Courts and Hon’ble Tribunal have held approval under section 153D as a mechanical approval without due application of mind by the approving authority. Moreover, content of the approval letter clearly establishes that while granting approval, the ITAs

Sudesh Chaudhary, Noida vs. DCIT, Central Circle- 1, Noida

ITA 2229/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Sept 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

significantly distinguishable from the fact all those cases where Hon’ble Courts and Hon’ble Tribunal have held approval under section 153D as a mechanical approval without due application of mind by the approving authority. Moreover, content of the approval letter clearly establishes that while granting approval, the ITAs

Braj Pal Singh, Noida vs. DCIT, Central Circle-1, Noida

ITA 2228/DEL/2022[016-17]Status: DisposedITAT Delhi29 Sept 2025

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 153D

significantly distinguishable from the fact all those cases where Hon'ble Courts and Hon'ble Tribunal have held approval under section 153D as a mechanical approval without due application of mind by the approving authority. Moreover, content of the approval letter clearly establishes that while granting approval, the 14 ITAS

Sudesh Chaudhary, Noida vs. DCIT, Central Cercle-1, Noida

ITA 2227/DEL/2022[2015-16]Status: DisposedITAT Delhi29 Sept 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan RFor Respondent: Shri Amit jain, CIT-DR
Section 132Section 132ASection 153Section 153D

significantly distinguishable from the fact all those cases where Hon’ble Courts and Hon’ble Tribunal have held approval under section 153D as a mechanical approval without due application of mind by the approving authority. Moreover, content of the approval letter clearly establishes that while granting approval, the ITAs

Sudesh Chaudhary, Noida vs. DCIT, Central Circle-1, Noida

ITA 2226/DEL/2022[2014-15]Status: DisposedITAT Delhi29 Sept 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Rajiv Khandelwal, Shri Gagan R
Section 153D

significantly distinguishable from the fact all those cases where Hon'ble Courts and Hon'ble Tribunal have held approval under section 153D as a mechanical approval without due application of mind by the approving authority. Moreover, content of the approval letter clearly establishes that while granting approval, the 14 ITAS

Aditya Sharma, New Delhi vs. ACIT, CC-19, New Delhi

In the result, appeal of the assessee is allowed

ITA 8405/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Sept 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Manish Agarwalआअसं.3622 और 8405 /िद"ी/2019 (िन.व. 2014-15)

For Appellant: S/Shri Ajay Wadwa, Shivam Garg & Harsh Raghav, &For Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153D

assessee at this belated stage. She submitted that the assessee never raised any objection before the Assessing Officer (AO) or the CIT(A) alleging mechanical approval u/s. 153D of the Act. 5. Submissions made by rival sides on the admission of additional ground of appeal heard. The additional ground raised ... spirit of section 153D of the Act. The ld. Counsel for the assessee placed reliance on the following decisions to contend that mechanical approval granted u/s. 153D of the Act is unsustainable, hence, vitiates the assessment proceedings:  ACIT vs. Serajuddin & Co.; [2023] 454 ITR 312 (Orissa);  ACIT vs. Serajuddin

DCIT, Central Circle- 7, New Delhi vs. Aditya Sharma, New Delhi

In the result, appeal of the assessee is allowed

ITA 5199/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Sept 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Manish Agarwalआअसं.3622 और 8405 /िद"ी/2019 (िन.व. 2014-15)

For Appellant: S/Shri Ajay Wadwa, Shivam Garg & Harsh Raghav, &For Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153D

assessee at this belated stage. She submitted that the assessee never raised any objection before the Assessing Officer (AO) or the CIT(A) alleging mechanical approval u/s. 153D of the Act. 5. Submissions made by rival sides on the admission of additional ground of appeal heard. The additional ground raised ... spirit of section 153D of the Act. The ld. Counsel for the assessee placed reliance on the following decisions to contend that mechanical approval granted u/s. 153D of the Act is unsustainable, hence, vitiates the assessment proceedings:  ACIT vs. Serajuddin & Co.; [2023] 454 ITR 312 (Orissa);  ACIT vs. Serajuddin

Aditya Sharma, New Delhi vs. ACIT Central Circle-19, New Delhi

In the result, appeal of the assessee is allowed

ITA 3622/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Sept 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Manish Agarwalआअसं.3622 और 8405 /िद"ी/2019 (िन.व. 2014-15)

For Appellant: S/Shri Ajay Wadwa, Shivam Garg & Harsh Raghav, &For Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 143(3)Section 148Section 153ASection 153D

assessee at this belated stage. She submitted that the assessee never raised any objection before the Assessing Officer (AO) or the CIT(A) alleging mechanical approval u/s. 153D of the Act. 5. Submissions made by rival sides on the admission of additional ground of appeal heard. The additional ground raised ... spirit of section 153D of the Act. The ld. Counsel for the assessee placed reliance on the following decisions to contend that mechanical approval granted u/s. 153D of the Act is unsustainable, hence, vitiates the assessment proceedings:  ACIT vs. Serajuddin & Co.; [2023] 454 ITR 312 (Orissa);  ACIT vs. Serajuddin

Avinandita Mohanty, Bhubaneswar vs. Deputy Commissioner of Income Tax, Central Circle-2, Bhuabenswar

In the result, appeals in ITA No

ITA 367/CTK/2025[2017-18]Status: DisposedITAT Cuttack24 Sept 2025AY 2017-18

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri K.C.Jena &Mohit Sheth, ArsFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 153D

evident that what he has found in each case have not discussed. In all the cases he has granted approval which is simply a mechanical approval. For this purpose it would be worthwhile to extract the approval given in other cases. In case of Sandhya Mohanty, the approval given

Avinandita Mohanty, Bhubaneswar vs. Deputy Commissioner of Income Tax, Central Circle-2 Bhuabenswar, Bhubaneswar

In the result, appeals in ITA No

ITA 365/CTK/2025[2012-13]Status: DisposedITAT Cuttack24 Sept 2025AY 2012-13

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri K.C.Jena &Mohit Sheth, ArsFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 153D

evident that what he has found in each case have not discussed. In all the cases he has granted approval which is simply a mechanical approval. For this purpose it would be worthwhile to extract the approval given in other cases. In case of Sandhya Mohanty, the approval given

Soumendra Kumar Mohanty, Bhubaneswar vs. Deputy Commissioner of Income Tax, Central Circle-2 Bhuabenswar, Bhubaneswar

In the result, appeals in ITA No

ITA 364/CTK/2025[2017-18]Status: DisposedITAT Cuttack24 Sept 2025AY 2017-18

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri K.C.Jena &Mohit Sheth, ArsFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 153D

evident that what he has found in each case have not discussed. In all the cases he has granted approval which is simply a mechanical approval. For this purpose it would be worthwhile to extract the approval given in other cases. In case of Sandhya Mohanty, the approval given

Nanak Chand Tayal, Faridabad Haryana vs. Dy Commissioner of Income Tax Central Circle 2 Faridabad, Faridabad Haryana

The appeals of the assessee are allowed

ITA 1615/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Sept 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 153ASection 153D

approval letter about the material supplied to him by the AO alongwith the draft assessment orders for his consideration and thus it is a mechanical approval given. He further states that the Addl. CIT was at Gurugram and the assessing officer was stationed at Faridabad and it is not possible ... Revenue supports the order of AO and submits that approval was not granted on the same day and not a mechanical approval. As per CBDT Circular dated 22.12.2006,the Range head i.e. the JCIT/ Addl. CIT is fully aware of the assessment proceedings and actively discussed with the AO from

Nanak Chand Tayal, Faridabad Haryana vs. Deputy Commissioner of Income Tax Central Circle 2 Faridabad, Faridabad Haryana

The appeals of the assessee are allowed

ITA 1614/DEL/2025[2016-17]Status: DisposedITAT Delhi24 Sept 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 153ASection 153D

approval letter about the material supplied to him by the AO alongwith the draft assessment orders for his consideration and thus it is a mechanical approval given. He further states that the Addl. CIT was at Gurugram and the assessing officer was stationed at Faridabad and it is not possible ... Revenue supports the order of AO and submits that approval was not granted on the same day and not a mechanical approval. As per CBDT Circular dated 22.12.2006,the Range head i.e. the JCIT/ Addl. CIT is fully aware of the assessment proceedings and actively discussed with the AO from

Nanak Chand Tayal, Faridabad Haryana vs. Deputy Commissioner of Income Tax Central Circle 2 Faridabad, Faridabad Haryana

The appeals of the assessee are allowed

ITA 1613/DEL/2025[2015-16]Status: DisposedITAT Delhi24 Sept 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 153ASection 153D

approval letter about the material supplied to him by the AO alongwith the draft assessment orders for his consideration and thus it is a mechanical approval given. He further states that the Addl. CIT was at Gurugram and the assessing officer was stationed at Faridabad and it is not possible ... Revenue supports the order of AO and submits that approval was not granted on the same day and not a mechanical approval. As per CBDT Circular dated 22.12.2006,the Range head i.e. the JCIT/ Addl. CIT is fully aware of the assessment proceedings and actively discussed with the AO from

Nanak Chand Tayal, Faridabad Haryana vs. Dy Commissioner of Income Tax, Faridabd Haryana

The appeals of the assessee are allowed

ITA 1612/DEL/2025[2014-15]Status: DisposedITAT Delhi24 Sept 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 153ASection 153D

approval letter about the material supplied to him by the AO alongwith the draft assessment orders for his consideration and thus it is a mechanical approval given. He further states that the Addl. CIT was at Gurugram and the assessing officer was stationed at Faridabad and it is not possible ... Revenue supports the order of AO and submits that approval was not granted on the same day and not a mechanical approval. As per CBDT Circular dated 22.12.2006,the Range head i.e. the JCIT/ Addl. CIT is fully aware of the assessment proceedings and actively discussed with the AO from

Nanak Chand Tayal, Faridabad Haryana vs. Deputy Comissioner of Income Tax Central Circle 2 Faridabad, Faridabad Haryana

The appeals of the assessee are allowed

ITA 1611/DEL/2025[2013-14]Status: DisposedITAT Delhi24 Sept 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 153ASection 153D

approval letter about the material supplied to him by the AO alongwith the draft assessment orders for his consideration and thus it is a mechanical approval given. He further states that the Addl. CIT was at Gurugram and the assessing officer was stationed at Faridabad and it is not possible ... Revenue supports the order of AO and submits that approval was not granted on the same day and not a mechanical approval. As per CBDT Circular dated 22.12.2006,the Range head i.e. the JCIT/ Addl. CIT is fully aware of the assessment proceedings and actively discussed with the AO from

Avon Containners Pvt. Ltd., Faridabad vs. ACIT, Circle-1, Faridabad

In the result, the appeal of the assessee is allowed as above

ITA 5161/DEL/2024[2012-13]Status: DisposedITAT Delhi23 Sept 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(3)Section 147Section 148Section 151

which the case was proposed for reopening. He thus, contended that this clearly demonstrated non-application of mind by the Range Head and mechanical approval by the Ld. PCIT under section 151 of the Act. Further, the Ld. AR drew our attention to the following two different reasons recorded ... approval granted under section 151(1) of the Act by the Ld. PCIT. On such anomalies in two reasons recorded by the AO and mechanically approved under section 151(1) of the Act by the Ld. PCIT, the Ld. AR contended that none of the reasons could be held valid

Income Tax Officer, Mohali Punjab vs. Taj Land Developefrs and Promoters Private Limited, Sector Mohali Punjab

In the result, appeal is dismissed

ITA 606/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh22 Sept 2025AY 2011-12
For Appellant: \nShri Sudhir Sehgal, AdvocateFor Respondent: \nSmt. Kusum Bansal, CIT DR
Section 139Section 147Section 148Section 151

been mentioned that the\nassessee has not filed any return of income u/s 139 or 142(1) and then, the fact\nof the mechanical approval is further borne out from Column 22 of the said\nproforma, where the PCIT has accorded her satisfaction on the basis that no\nreturn ... column in paragraph 22 are already typed and only some blank\ncolumns have been filled, which proves that it is only a mechanical approval by\nthe PCIT and in view of the above said judgements as cited by the assessee and\nalso the recent judgment of Chandigarh Bench

Vasudev Garg, Faridabad vs. DCIT Central Circle 1 Faridabad, Faridabad

ITA 3176/DEL/2025[2019-20]Status: DisposedITAT Delhi22 Sept 2025AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 3169/Del/2025 : Asstt. Year : 2012-13 Ita No. 3170/Del/2025 : Asstt. Year : 2013-14 Ita No. 3171/Del/2025 : Asstt. Year : 2014-15 Ita No. 3172/Del/2025 : Asstt. Year : 2015-16 Ita No. 3173/Del/2025 : Asstt. Year : 2016-17 Ita No. 3174/Del/2025 : Asstt. Year : 2017-18 Ita No. 3175/Del/2025 : Asstt. Year : 2018-19 Ita No. 3176/Del/2025 : Asstt. Year : 2019-20 Vasudev Garg, Vs Dcit, Fca 50, Mukesh Colony, Ballabgarh, Central Circle-1, Faridabad, Haryana-121004 Faridabad, Haryana-121001 (Appellant) (Respondent) Pan No. Aflpg8975Q Assessee By : Dr. Rakesh Gupta, Adv. & Sh. Somil Agarwal, Adv. Revenue By : Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing: 22.09.2025 Date Of Pronouncement: 22.09.2025 Order Per Satbeer Singh Godara: The Assessee’S Eight Appeals

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Sh. Dayainder Singh Sidhu, CIT-DR
Section 143(3)Section 153ASection 153DSection 254(1)

before the approving authority. Hence, the allegation that approval was granted without consideration of seized material is devoid of merit. 4. No Inference of Mechanical Approval  The approval letter itself makes it evident that the Addl. CIT had perused the assessment records and seized material. Accordingly, it cannot be inferred ... informed about the facts and issues. The fact that approval was granted on the same day as receipt of the proposal does not imply mechanical approval. 6. Approval - A Question of Fact The Hon’ble Jurisdictional High Court has repeatedly held that validity of approval under section 153D is essentially