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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

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

Banarsi Lal, Firozabad vs. ITO 2(2)(1), Firozabad

In the result, the appeal of the assessee is allowed

ITA 317/AGR/2025[2014-2015]Status: DisposedITAT Agra20 Mar 2026AY 2014-2015

Bench: Us Challenging The Validity Of Assumption Of Jurisdiction U/S 147 Of The Act. These Additional Grounds Go To The Root Of The Matter & The Facts Relevant For Its Adjudication Are Placed On Record. Hence, We Admit The Additional Grounds & Take Up The Same First For Adjudication.

Section 147Section 148Section 151Section 250

granting approval in terms of section 151 of the Act. This approval was held by the Hon’ble Delhi High court to be a mechanical approval. The Hon’ble Delhi High Court in the recent decision in the case of SBC Minerals P Ltd. vs ACIT reported

Swift Impex Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-27, New Delhi

In the result, all the six appeals of the assessee are allowed

ITA 4924/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 153CSection 153DSection 3

153D of the Act as mechanical having been granted without independent satisfaction and non-application of mind. 17. Thus, the assessment order based on mechanical approval stand vitiated and is hereby quashed by allowing the ground no. 4 and 5 of appeal taken by the assessee. 15 18. Since ... raised in these appeals regarding approval u/s 153D of the Act, being mechanical, are allowed. Thus, the assessment order based on mechanical approval stand vitiated and is hereby quashed by allowing the ground no. 4 and 5 of appeal taken by the assessee. The other grounds in view of quashing

Swift Impex Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-27, New Delhi

In the result, all the six appeals of the assessee are allowed

ITA 4922/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 153CSection 153DSection 3

153D of the Act as mechanical having been granted without independent satisfaction and non-application of mind. 17. Thus, the assessment order based on mechanical approval stand vitiated and is hereby quashed by allowing the ground no. 4 and 5 of appeal taken by the assessee. 15 18. Since ... raised in these appeals regarding approval u/s 153D of the Act, being mechanical, are allowed. Thus, the assessment order based on mechanical approval stand vitiated and is hereby quashed by allowing the ground no. 4 and 5 of appeal taken by the assessee. The other grounds in view of quashing

Swift Impex Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Central Circle-27, New Delhi

In the result, all the six appeals of the assessee are allowed

ITA 4919/DEL/2025[2015-16]Status: DisposedITAT Delhi20 Mar 2026AY 2015-16

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sumit Lalchandani, AdvFor Respondent: Ms. Pooja Swaroop, CIT(DR)
Section 153CSection 153DSection 3

153D of the Act as mechanical having been granted without independent satisfaction and non-application of mind. 17. Thus, the assessment order based on mechanical approval stand vitiated and is hereby quashed by allowing the ground no. 4 and 5 of appeal taken by the assessee. 15 18. Since ... raised in these appeals regarding approval u/s 153D of the Act, being mechanical, are allowed. Thus, the assessment order based on mechanical approval stand vitiated and is hereby quashed by allowing the ground no. 4 and 5 of appeal taken by the assessee. The other grounds in view of quashing

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

In the result, appeal filed by the assessee is allowed in above terms and the appeal of the Revenue is dismissed

ITA 8069/DEL/2025[2013-14]Status: DisposedITAT Delhi18 Mar 2026AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 132ASection 153DSection 28

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 ... 153D do not require the JCIT to record satisfaction in any specific format or language. The appellant has failed to substantiate its claim of mechanical approval. No evidence was provided to demonstrate non-application of mind by the JCIT. The approval under section 153D was validly granted. This ground

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

In the result, appeal filed by the assessee is allowed in above terms and the appeal of the Revenue is dismissed

ITA 6383/DEL/2025[2013-14]Status: DisposedITAT Delhi18 Mar 2026AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 132ASection 153DSection 28

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 ... 153D do not require the JCIT to record satisfaction in any specific format or language. The appellant has failed to substantiate its claim of mechanical approval. No evidence was provided to demonstrate non-application of mind by the JCIT. The approval under section 153D was validly granted. This ground

ACIT, New Delhi vs. Corporate International Financial Services Limited, Delhi

In the result, Cross Objection No

ITA 4806/DEL/2025[2013-14]Status: DisposedITAT Delhi18 Mar 2026AY 2013-14

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalassistant Commissioner Of Income Vs Corporate International Tax, Central Cordcle-04, Room No. Financial Services Limited 333, 3Rd Floor, Ara Centre, Sector B Pkt-1, Vasant Jhandewalan Extension , New Delhi Kunj, South Delhi, Delhi Pan: Aaack0329B Appellant Respondent C.O No. 270/Del/2025 In Ita No. 4806/Del/2025 Corporate International Financial Vs Assistant Commissioner Of Services Limited Income Tax, Central Sector B Pkt-1, Vasant Kunj, South Cordcle-04, Room No. 333, Delhi, Delhi 3Rd Floor, Ara Centre, Pan: Aaack0329B Jhandewalan Extension , New Delhi Appellant Respondent Assessee By Sh. Somil Aggarwal, Adv & Sh. Deepesh Garg, Adv Revenue By Sh. Dayainder Singh Sidhu, Cit Dr Date Of Hearing 16/03/2026 Date Of Pronouncement 18/03/2026 Order Per Yogesh Kumar, U.S. Jm: The Captioned Appeal Is Filed By The Revenue & The Cross Objection Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax Appeal, (Ld. Cit(A) For Short) Delhi-23 Dated 24/04/2025 Pertaining To Assessment Year 2013-14. 2. The Ld. Counsel For The Assessee Addressing On The Ground No. 3 Of Cross Objection, Contended That The Assessment Order Has Been Passed Based On The Invalid Approval Accorded Under Section 153D Of 2Ita No. 4806/D/2025 & C.O. No. 270/D/2025 Acit Vs. Corporate International

Section 153D

Objection filed by the Assessee and quash the subject assessment order. Since, we have quashed the assessment order on the ground of invalid and mechanical approval 10 ITA No. 4806/D/2025 & C.O. No. 270/D/2025 ACIT Vs. Corporate International u/s 153D of the Act, the Appeal filed by the Revenue challenging

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1594/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl
Section 115BSection 143(3)Section 65BSection 69C

raised by the assessee as well as the revenue stand dismissed. 8. In one of the grounds, the assessee has raised the issue of mechanical approval u/s 153D. This issue has also been dealt with by us in cross-appeals for AY 2020-21 (supra) as under ... grounds, the assessee has raised the issue of mechanical approval u/s 153D. On the issue of approval u/s 153D, Ld. CIT(A), at paras 12.1 to 12.4 of the impugned order, noted that Ld. AO sent the draft assessment order along with assessment record to Addl. CIT and the requisite

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1593/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –
Section 115BSection 153A(1)(b)Section 153DSection 65BSection 68Section 69C

toto. The assessee succeeds in its corresponding grounds of appeal. 7. In one of the grounds, the assessee has raised the issue of mechanical approval u/s 153D. On the issue of approval u/s 153D, Ld. CIT(A), at paras 12.1 to 12.4 of the impugned order, noted that ... duly considered the 21 issues involved in the draft assessment order and made the perusal of assessment record. The allegation that the approval was mechanical approval had no basis. In Central charges, all search and seizure assessments are regularly supervised and monitored by the range heads. The Addl

Saraf the Jeweller, Chandigarh vs. The DCIT/ACIT Central Circle- 2, Chandigarh

Appeal stand dismissed

ITA 1232/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl
Section 115BSection 143(3)Section 65BSection 69C

raised by the assessee as well as the revenue stand dismissed. 8. In one of the grounds, the assessee has raised the issue of mechanical approval u/s 153D. This issue has also been dealt with by us in cross-appeals for AY 2020-21 (supra) as under ... grounds, the assessee has raised the issue of mechanical approval u/s 153D. On the issue of approval u/s 153D, Ld. CIT(A), at paras 12.1 to 12.4 of the impugned order, noted that Ld. AO sent the draft assessment order along with assessment record to Addl. CIT and the requisite

Saraf the Jeweller, Chandigarh vs. The DCIT/ACIT Central Circle -2, Chandigarh

Appeal stand dismissed

ITA 1231/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –
Section 115BSection 153A(1)(b)Section 153DSection 65BSection 68Section 69C

toto. The assessee succeeds in its corresponding grounds of appeal. 7. In one of the grounds, the assessee has raised the issue of mechanical approval u/s 153D. On the issue of approval u/s 153D, Ld. CIT(A), at paras 12.1 to 12.4 of the impugned order, noted that ... duly considered the 21 issues involved in the draft assessment order and made the perusal of assessment record. The allegation that the approval was mechanical approval had no basis. In Central charges, all search and seizure assessments are regularly supervised and monitored by the range heads. The Addl

Alok & Co LLP, Delhi vs. DCIT, Central Circle-28, Delhi

In the result, appeal filed by the assessee are partly allowed

ITA 2736/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 153CSection 153DSection 65BSection 69A

satisfaction recorded had any bearing to the total income of the assessee. 10. Coming to the next issue raised by the assessee on mechanical approval granted u/s 153D of the Act, after careful consideration of the fact on record, we observed that the draft assessment order was forward

Alok & Co LLP, Delhi vs. DCIT, Central Circle-28, Delhi

In the result, appeal filed by the assessee are partly allowed

ITA 2735/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 153CSection 153DSection 65BSection 69A

satisfaction recorded had any bearing to the total income of the assessee. 10. Coming to the next issue raised by the assessee on mechanical approval granted u/s 153D of the Act, after careful consideration of the fact on record, we observed that the draft assessment order was forward

Aanchal Impex Pvt Ltd, New Delhi vs. ITO Ward - 1(1), New Delhi

Appeal is allowed

ITA 9089/DEL/2019[2007-08]Status: DisposedITAT Delhi11 Mar 2026AY 2007-08

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 147Section 151

independent mind thereupon. 3. We thus are of the considered view that the impugned reopening itself is invalid since based on a mere mechanical approval of the said prescribed authority in light of CIT Vs. S. Goyanka Lime and Chemical Pvt. Ltd. (2015) 64 taxmann.com 313 (SC) to quash

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, the appeal of the assessee is allowed

ITA 4/ALLD/2019[2011-12]Status: DisposedITAT Allahabad10 Mar 2026AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y.-2011-12 Vijay Stone Product, Vs. Asstt. Commissioner Of Income Bari Dala, Sonebhadra-231001 Tax, Central Circle, Allahabad Pan: Aagfv4724J (Appellant) (Respondent) Assessee By: Sh. Praveen Godbole, C.A. Revenue By: Sh. Amalendu Nath Mishra, Cit Dr Date Of Hearing: 17.12.2025 Date Of Pronouncement: 10.03.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A)- 3, Lucknow Dated 29.10.2018 Wherein The Ld. Cit(A) Has Confirmed A Penalty Of Rs. 1 Lac Levied By The Assessing Officer Under Section 221 Of The Act Against The Total Levy Of Rs. 27,26,200/- Made By The Assessing Officer. The Grounds Of Appeal Are As Under:- “1. That In Any View Of The Matter Order Passed U/S 221(1) Of The It Act Imposing Huge Penalty & His Action As Partly Confirmed By The Commissioner Of Income Tax (Appeal) By Maintaining Penalty Of Rs. 1,00,000/- Is Unjustified & Incorrect In The Facts & Circumstances Of The Case. 2. That In Any View Of The Matter Tax Liability On The Basis Of Assessment Order As Created Is Not Correct At All Therefore The Question Of Maintaining Penalty Of Rs. 1,00,000/- Is Unwarranted In The Facts & Circumstances Of The Case. 3. That In Any View Of The Matter In The Facts & Circumstances Of The Case Penalty Order Passed By The Assessing Officer & His Action As Partly Confirmed By The Commissioner Of Income Tax (Appeal) Is Totally Incorrect & Illegal & Hence The Question Of Maintaining Penalty Does Not Arise & Therefore So Maintained Penalty Is Liable To Be Deleted In All Fairness & In Interest Of Justice.

For Appellant: Sh. Praveen Godbole, C.AFor Respondent: Sh. Amalendu Nath Mishra, CIT DR
Section 153DSection 153D(1)(B)Section 220(2)Section 221Section 221(1)Section 276C(2)

approval granted by the JCIT, Central Range, Lucknow under section 153D of the Act without examination of records and seized materials, was a mechanical approval which vitiated the appeal and made it a nullity in the eyes of law. On closure examination of the file, it is found that neither

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1592/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh10 Mar 2026AY 2019-20

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1230/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1592/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 10.03.2026 : आदेश / O R D E R Per Bench 1.1 Aforesaid Cross-Appeals For Assessment Year (Ay) 2019-20Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals)-3

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –
Section 115BSection 132Section 153A(1)(b)Section 153DSection 65BSection 68

impugned addition, we allow the corresponding grounds of assessee’s appeal. 13. In one of the grounds, the assessee has raised the issue of mechanical approval u/s 153D.On the issue of approval u/s 153D, Ld. CIT(A) noted that Ld. AO sent the draft assessment order along with assessment record ... duly considered the issues 23 involved in the draft assessment order and made the perusal of assessment record. The allegation that the approval was mechanical approval had no basis. In Central charges, all search and seizure assessments are regularly supervised and monitored by the range heads. The Addl

Kewal Krishan, Chandigarh vs. Joa DCIT/ACIT/JCIT(OSD)(Central Circle) 1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1275/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-24

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

such, the same is treated as withdrawn and dismissed accordingly. 31. The assessee has withdrawn the grounds of appeal with regard to mechanical approval and the issue of notice u/s 148 in the above appeals as stated above and both the Ld. Counsel and Ld. CIT (DR) agreed that

Kewal Krishan Chandigarh, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) (Central Circle) 1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1274/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh10 Mar 2026AY 2021-22
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

such, the same is treated as withdrawn and dismissed accordingly. 31. The assessee has withdrawn the grounds of appeal with regard to mechanical approval and the issue of notice u/s 148 in the above appeals as stated above and both the Ld. Counsel and Ld. CIT (DR) agreed that

Kewal Krishan, Chandigarh vs. Jao DCIT/ACIT JCIT (OSD)(Central Circle)-1, Chandigarh.

In the result, all the above appeals are partly allowed

ITA 1273/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-21
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

such, the same is treated as withdrawn and dismissed accordingly. 31. The assessee has withdrawn the grounds of appeal with regard to mechanical approval and the issue of notice u/s 148 in the above appeals as stated above and both the Ld. Counsel and Ld. CIT (DR) agreed that

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1272/CHANDI/2025[2023-2024]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-2024

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

such, the same is treated as withdrawn and dismissed accordingly. 31. The assessee has withdrawn the grounds of appeal with regard to mechanical approval and the issue of notice u/s 148 in the above appeals as stated above and both the Ld. Counsel and Ld. CIT (DR) agreed that