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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

Kalpana Ramesh Jain, Mumbai vs. Deputy Commissioner of Income Tax- Central Circle-4(3)(1), Mumbai

In the result all the three appeals of the assessee are allowed

ITA 4597/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Shri Mani Jain a/w Shri Prateek
Section 10(38)Section 147Section 148Section 68

that since the reasons recorded themselves suffer from factual inaccuracies and non-application of mind, the sanction obtained for reopening is equally vitiated. A mechanical approval based on erroneous reasons cannot cure the inherent jurisdictional defect and defeats the statutory safeguard built into the Act. 4.5 In view

Kalpana Ramesh Jain, Mumbai vs. Deputy Commissioner of Income Tax- Central Circle-4(3)(1), Mumbai

In the result all the three appeals of the assessee are allowed

ITA 4595/MUM/2025[2015-16]Status: DisposedITAT Mumbai04 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Shri Mani Jain a/w Shri Prateek
Section 10(38)Section 147Section 148Section 68

that since the reasons recorded themselves suffer from factual inaccuracies and non-application of mind, the sanction obtained for reopening is equally vitiated. A mechanical approval based on erroneous reasons cannot cure the inherent jurisdictional defect and defeats the statutory safeguard built into the Act. 4.5 In view

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

ITA 2712/DEL/2025[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 149(1)(b)Section 250

reassessment cases carrying serious civil consequences are framed only after due, conscious, and independent application of mind by the approving authority. Facts Demonstrating Mechanical Approval 4. In the present case, the approval under Section 148B of the Act was granted in a routine, perfunctory, and mechanical manner, as is evident

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

ITA 2709/DEL/2025[2014-15]Status: DisposedITAT Delhi04 Feb 2026AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 149(1)(b)Section 250

reassessment cases carrying serious civil consequences are framed only after due, conscious, and independent application of mind by the approving authority. Facts Demonstrating Mechanical Approval 4. In the present case, the approval under Section 148B of the Act was granted in a routine, perfunctory, and mechanical manner, as is evident ... Chaudhary v. Assistant Commissioner of Income Tax, CC 8 New Delhi (Third Member) - ITA Nos. 6158 to 6160/Del/2018 [ITAT Delhi] Judicial Precedents against Consolidated / Mechanical Approval under Section 148B of the Act 12 Reliance is also placed on the decision of the Hon'ble Delhi Bench of the Tribunal

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

ITA 2708/DEL/2025[2013-14]Status: DisposedITAT Delhi04 Feb 2026AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

reassessment cases carrying serious civil consequences are framed only after due, conscious, and independent application of mind by the approving authority. Facts Demonstrating Mechanical Approval 4. In the present case, the approval under Section 148B of the Act was granted in a routine, perfunctory, and mechanical manner, as is evident ... Chaudhary v. Assistant Commissioner of Income Tax, CC 8 New Delhi (Third Member) - ITA Nos. 6158 to 6160/Del/2018 [ITAT Delhi] Judicial Precedents against Consolidated / Mechanical Approval under Section 148B of the Act ITA Nos.4153,4008, 2708 to 2717/Del/2025 12 Reliance is also placed on the decision

Karan Israni, New Delhi vs. DCIT, Central Circle-30, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1627/DEL/2025[2019-20]Status: DisposedITAT Delhi04 Feb 2026AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Muneesh Rajani, Sr. DR
Section 132Section 142(1)Section 153C

require the Additional CIT 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 Additional CIT. The approval under section 153D was validly granted. This ground is dismissed

M/S Credo Assets Pvt. Ltd., Rupnagar Punjab vs. DCIT/ACIT(Cen)-1 Chd, Chandigarh

The appeals stand partly allowed

ITA 484/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh03 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

For Appellant: Sh. Parikshit Aggarwal (CA) & Smt. ShrutiFor Respondent: Smt. Kusum Bansal (CIT) & Shri Rajat Kumar
Section 127Section 132Section 142ASection 143(3)Section 153ASection 153BSection 69ASection 69B

other arguments as raised by the assessee were also rejected and the addition of Rs.108 Lacs was confirmed. 4.19 On the issue of mechanical approval u/s 153D, it was held that the approval was accorded after due examination of relevant record and verification by the range head. Further, the approval ... Therefore, the assumption of jurisdiction was vitiated. We order so. The assessee succeeds in its respective grounds of appeal. The other legal grounds viz. mechanical approval as urged by Ld. AR has been rendered infructuous. 19. In the result, the appeal of the assessee stands partly allowed in terms

Devinder Singh, New Delhi vs. Income Tax Officer, Civic Centre, New Delhi

Appeal is allowed

ITA 6746/DEL/2025[2019-20]Status: DisposedITAT Delhi02 Feb 2026AY 2019-20

Bench: Shri Satbeer Singh Godara**

Section 147Section 151

independent mind thereupon. 3. Thus, I am 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

ACIT, Central Circle-19, Delhi vs. Yasmin Kapoor, Delhi

ITA 3379/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Jan 2026AY 2016-17

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhan

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

gross contravention of provisions of section 153D of the act being necessary approval accorded by Ld. Jt. CIT, Central Range 5, Delhi was a mechanical approval and assessment completed on the basis of said approval is bad in law and deserves to be quashed.” 7. The assessee (Yasmin Kapoor ... gross contravention of provisions of section 153D of the act being necessary approval accorded by Ld. Jt. CIT, Central Range 5, Delhi was a mechanical approval and assessment completed on the basis of said approval is bad in law and deserves to be quashed.” 9. We have heard the rival

ACIT, Central Circle-19, Delhi vs. Yasmin Kapoor, Delhi

Appeals of the assessee are allowed

ITA 2221/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

gross contravention of provisions of section 153D of the act being necessary approval accorded by Ld. Jt. CIT, Central Range 5, Delhi was a mechanical approval and assessment completed on the basis of said approval is bad in law and deserves to be quashed.” 7. The assessee (Yasmin Kapoor ... gross contravention of provisions of section 153D of the act being necessary approval accorded by Ld. Jt. CIT, Central Range 5, Delhi was a mechanical approval and assessment completed on the basis of said approval is bad in law and deserves to be quashed.” 9. We have heard the rival

ACIT, Central Circle-19, Delhi vs. Deepa Talwar, Delhi

Appeals of the assessee are allowed

ITA 2203/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

gross contravention of provisions of section 153D of the act being necessary approval accorded by Ld. Jt. CIT, Central Range 5, Delhi was a mechanical approval and assessment completed on the basis of said approval is bad in law and deserves to be quashed.” 7. The assessee (Yasmin Kapoor ... gross contravention of provisions of section 153D of the act being necessary approval accorded by Ld. Jt. CIT, Central Range 5, Delhi was a mechanical approval and assessment completed on the basis of said approval is bad in law and deserves to be quashed.” 9. We have heard the rival

Yasmin Kapoor, Delhi vs. DCIT, Central Circle - 19, Delhi

ITA 1542/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Jan 2026AY 2016-17

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhan

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

gross contravention of provisions of section 153D of the act being necessary approval accorded by Ld. Jt. CIT, Central Range 5, Delhi was a mechanical approval and assessment completed on the basis of said approval is bad in law and deserves to be quashed.” 7. The assessee (Yasmin Kapoor ... gross contravention of provisions of section 153D of the act being necessary approval accorded by Ld. Jt. CIT, Central Range 5, Delhi was a mechanical approval and assessment completed on the basis of said approval is bad in law and deserves to be quashed.” 9. We have heard the rival

Rita Das, Hooghly vs. I.T.O., Ward - 23(1), Hooghly

In the result, both the appeals of the assessee are allowed

ITA 1389/KOL/2024[2011-2012]Status: DisposedITAT Kolkata29 Jan 2026AY 2011-2012

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.1388 & 1389/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2011-2012) Rita Das, Vs Acit, Cc-23 (1), Hooghly C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata,Wb-700001 Pan No. :Arhpd 6149 D

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri Altaf Hussain, Sr. DR

disposing of the two objections raised by the assessee for the re-opening proceedings. 6. It was submission that the approval is a mechanical approval and the same is liable to be quashed. 7. In reply, the Ld.Sr DR submitted that the reasons are validly recorded and the satisfaction

Rita Das, Hooghly vs. I.T.O., Ward - 23(1), Hooghly

In the result, both the appeals of the assessee are allowed

ITA 1388/KOL/2024[2011-2012]Status: DisposedITAT Kolkata29 Jan 2026AY 2011-2012

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.1388 & 1389/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2011-2012) Rita Das, Vs Acit, Cc-23 (1), Hooghly C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata,Wb-700001 Pan No. :Arhpd 6149 D

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri Altaf Hussain, Sr. DR

disposing of the two objections raised by the assessee for the re-opening proceedings. 6. It was submission that the approval is a mechanical approval and the same is liable to be quashed. 7. In reply, the Ld.Sr DR submitted that the reasons are validly recorded and the satisfaction

Income Tax Officer 15(3)(1), Mumbai vs. Vpcg Exim Pvt Ltd, Mumbai

ITA 6028/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Jan 2026AY 2018-19

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethito-15(3)(1). Vs. Vpcg Exim Pvt. Ltd. Room No.456, 4Th Floor, 221, 2Nd Floor, Powai Plaza, Hiranandani Aayakar Bhawan, M.K. Gardens, Powai, Mumbai-400076. Road, Mumbai-400020. Pan/Gir No: Aaecv7799L (Appellant) (Respondent)

Section 132Section 148Section 250Section 68

well as law on the subject, the learned CIT(A) has erred in confirming action of Assessing Officer in recording the satisfaction by taking mechanical approval from the Principal Commissioner of Income Tax which is not supported by the generation of DIN. 3. On the facts and in the circumstance

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

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

Deputy Commissioner of Income Tax, Delhi vs. Gaurav Dalmia, Delhi

In the result, additional ground 1 under Rule 27 of the assessee is

ITA 4162/DEL/2025[2016-17]Status: DisposedITAT Delhi29 Jan 2026AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 132(4)Section 153ASection 153DSection 69A

ITAT for the first time, we are of the considered view that the approval u/s 153D was without application of mind or was mechanical approval, is not borne Page 7 of 30 ITA No.4162/DEL/2025 [A.Y 2016-17] The Dy. C.I.T. Vs. Gaurav Dalmia out from the relevant facts on record

DCIT, CC-18, New Delhi, Delhi vs. Jagat Agro Commodties Pv. Ltd., Delhi

In the result, both the appeals of the Revenue are dismissed in the aforesaid manner

ITA 1883/DEL/2021[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Salil Agarwal, Sr. Adv., Sh. Shailesh GuptaFor Respondent: Ms. Monika Singh, CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 148Section 69C

without there being any tangible material whatsoever and fishing and roving enquiries not permissible and also approval granted by the PCIT is a mechanical approval and hence, initiation of proceedings under section 147 of the Act on this ground is invalid. 5. Per contra, the Ld. Departmental Representative relied upon

DCIT, CC-18, New Delhi, Delhi vs. Jagat Agro Commodties Pv. Ltd., Delhi

In the result, both the appeals of the Revenue are dismissed in the aforesaid manner

ITA 1882/DEL/2021[2011-12]Status: DisposedITAT Delhi29 Jan 2026AY 2011-12

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Salil Agarwal, Sr. Adv., Sh. Shailesh GuptaFor Respondent: Ms. Monika Singh, CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 148Section 69C

without there being any tangible material whatsoever and fishing and roving enquiries not permissible and also approval granted by the PCIT is a mechanical approval and hence, initiation of proceedings under section 147 of the Act on this ground is invalid. 5. Per contra, the Ld. Departmental Representative relied upon

DCIT, Circle - 19(1), Delhi vs. Ramayna Ispat Pvt. Ltd., Delhi

In the result, the appeal of the assessee and Revenue are dismissed

ITA 4147/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalramayna Ispat Private Limited, Dcit, A-48, 1St Floor, Wazirpur Circle-19(1), Industrial Area, Delhi-110052. Vs. New Delhi. Pan-Aaccr7382R (Appellant) (Respondent) Dcit, Ramayna Ispat Private Limited, A-48, 1St Floor, Wazirpur Circle-19(1), New Delhi. Vs. Industrial Area, Delhi-110052. Pan-Aaccr7382R (Appellant) (Respondent) Assessee By Shri Maneesh Upneja, Ca, Shri Baldev Raj, Ca & Ms. Sanju Kumari, Adv. Department By Shri Khitesh Gupta, Sr. Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 27/11/2025 O R D E R Per Manish Agarwal, Am: These Cross Appeals Are Filed By The Assessee & Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Ld. Cit(A)] Dated 11.07.2024 U/S 250 Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2018-19. Ramayna Ispat Pvt. Ltd. Vs. Ito 2. Brief Facts Of The Case Are That The Assessee Is A Private Ltd. Company Engaged In The Business Of Manufacturing, Processing, Forging, Casting Mixing Of Various Kinds Of Steel, Carbon Settle, Mild Steel, Stainless Steel, High Speed Steel & Bright Steel Etc. The Return Of Income Was Revised On 28.10.2018 At An Income Of Rs.1,00,96,587/-. The Case Of The Assessee Was Reopened U/S 148 For The Reason That Assessee Has Taken Accommodation Entries Of Bogus Purchases & After Considering The Submissions Made, Ao Had Made The Addition Of Rs.5,78,99,593/- U/S 69C Of The Act Towards Unexplained Expenditure On Account Of Bogus Purchase & Further Invoked The Provisions Of Section 115Bbe Of The Act. The Ao Further Made An Addition Of Rs.3,14,795/- By Estimating The Net Profit Declared By The Assessee. Besides This Further Disallowance Of Rs.9,37,608/- Was Made Out Of Freight Expenses And, Accordingly, The Total Income Of The Assessee Was Assessed At Rs.6,87,83,788/-.

Section 115BSection 147Section 148Section 250Section 690Section 69C

only Ramayna Ispat Pvt. Ltd. vs. ITO on the basis of information as received from the Investigation Wing. c. Based upon a mechanical approval from the superior authorities. d. Based upon the documents/information which was un-earth during the course of search of some other entity. 3. On facts