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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

Ramayna Ispat Private Limited, New Delhi vs. The Deputy Commissioner of Income Tax, Circle-19(1), New Delhi

ITA 4138/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 115BSection 147Section 148Section 250Section 69C

implementation of mind by the Ld. AO and only 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

DCIT, New Delhi vs. Sh. Ramesh Sharma, New Delhi

In the result, the appeal of the Revenue is dismissed in the aforesaid manner

ITA 6881/DEL/2014[2010-11]Status: DisposedITAT Delhi23 Jan 2026AY 2010-11

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

For Appellant: Sh. Salil Agarwal, Sr. Adv. &For Respondent: Ms. Monika Singh, CIT(DR)
Section 132Section 143(2)Section 153A

common approval number makes it amply clear that the approval accorded under section 153D of the Act in the instant case is a mechanical approval without there being separate approval for “each assessment year”. He relied upon the decision of the Coordinate Bench in the case of the assessee ... amply clear that the common approval with common numbers have been accorded under section 153D of the Act in the instant case is a mechanical approval. We further find that the Coordinate Bench in the case of the assessee’s wife namely Smt. Usha Sharma in ITA No. 480/Del/2015 under

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

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

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

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

Vikas Chandra HUF, Aligarh vs. ITO Ward-4(1)(1), Aligarh

In the result, the appeal of the assessee is allowed

ITA 450/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Pankaj Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 139(1)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 Delhi High Court in this regard are reproduced herein:- “11. Section 151 of the Act clearly stipulates

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

ITA 1104/HYD/2025[2015-16]Status: DisposedITAT Hyderabad21 Jan 2026AY 2015-16

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 153CSection 153D

case of Navin Jain (supra) has been relied by the Tribunal, in the instant case, to arrive at the conclusion that the mechanical approval under section 153D of the Act would vitiate the entire proceedings in the instant case. 18. For the reasoning given in the case of Navin Jain ... Section 153D or granting of approval without proper examination can lead to the invalidation of the assessment order. It was observed that a mere mechanical approval without proper examination and understanding of the draft assessment order or case records of the case vitiated the assessment order. Based on the aforesaid

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

ITA 1103/HYD/2025[2014-15]Status: DisposedITAT Hyderabad21 Jan 2026AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 153CSection 153D

case of Navin Jain (supra) has been relied by the Tribunal, in the instant case, to arrive at the conclusion that the mechanical approval under section 153D of the Act would vitiate the entire proceedings in the instant case. 18. For the reasoning given in the case of Navin Jain ... Section 153D or granting of approval without proper examination can lead to the invalidation of the assessment order. It was observed that a mere mechanical approval without proper examination and understanding of the draft assessment order or case records of the case vitiated the assessment order. Based on the aforesaid

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. DCIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

ITA 1102/HYD/2025[2013-14]Status: DisposedITAT Hyderabad21 Jan 2026AY 2013-14

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 153CSection 153D

case of Navin Jain (supra) has been relied by the Tribunal, in the instant case, to arrive at the conclusion that the mechanical approval under section 153D of the Act would vitiate the entire proceedings in the instant case. 18. For the reasoning given in the case of Navin Jain ... Section 153D or granting of approval without proper examination can lead to the invalidation of the assessment order. It was observed that a mere mechanical approval without proper examination and understanding of the draft assessment order or case records of the case vitiated the assessment order. Based on the aforesaid

Swastik Vegetable Oil Products Private Limited, Hyderabad vs. ACIT., Central Circle - 2(1), Hyderabad

In the result, the appeals of the assessee company in ITA Nos

ITA 1101/HYD/2025[2012-13]Status: DisposedITAT Hyderabad21 Jan 2026AY 2012-13

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1101, 1102, 1103, 1104 & 1105/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2012-13 To 2016-17) Swastik Vegetable Oil Vs. Assistant Commissioner Products Private Limited, Of Income Tax, Hyderabad. Central Circle-2(1), Pan: Aadcs2224G Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siddharth Toshnival, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 21/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Company Are Directed Against The Respective Orders Passed By The Cit(Appeals), Dated 19.03.2025, Which In Turn Arises From The Orders Passed By The Ao Under Section 143(3) R.W. Section 153C Of The Income- Tax Act, 1961, Dated 31.05.2021, For The Assessment Years 2012-13 To 2016-17. As Certain Common Issues Are Involved In The Present Appeals, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Private Limited Vs. Acit

For Appellant: Shri Siddharth ToshnivalFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 153CSection 153D

case of Navin Jain (supra) has been relied by the Tribunal, in the instant case, to arrive at the conclusion that the mechanical approval under section 153D of the Act would vitiate the entire proceedings in the instant case. 18. For the reasoning given in the case of Navin Jain ... Section 153D or granting of approval without proper examination can lead to the invalidation of the assessment order. It was observed that a mere mechanical approval without proper examination and understanding of the draft assessment order or case records of the case vitiated the assessment order. Based on the aforesaid

Sunil Jindal, Faridabad Haryana vs. Deputy Commissioner of Income Tax, Faridabad, Haryana

In the result, the appeal of the assessee is allowed

ITA 2542/DEL/2025[2018-19]Status: DisposedITAT Delhi21 Jan 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 127Section 132Section 142(1)Section 143(2)Section 153ASection 250Section 68

assessee submitted that in the present case, approval was granted by ld. Addl. CIT, Central Range, Gurugram vide letter dated 20.04.2021 which is mechanical approval. Ld. AR further submits that ld. Addl. CIT granted common approval for various Assessment Years from 2013-14 to 2019-20 in terms of letter ... dated 20.04.2021. He submits that from the perusal of the same it could be seen that approval granted by the Id. Adl. CIT was mechanical approval and separate approval for each Assessment Year was not given rather approval was given by a single order for various assessment years. The letter

Sunil Jindal, Faridabad Haryana vs. Deputy Commissioner of Income Tax, Faridabad, Haryana

In the result, the appeal of the assessee is allowed

ITA 2541/DEL/2025[2017-18]Status: DisposedITAT Delhi21 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 127Section 132Section 142(1)Section 143(2)Section 153ASection 250Section 68

assessee submitted that in the present case, approval was granted by ld. Addl. CIT, Central Range, Gurugram vide letter dated 20.04.2021 which is mechanical approval. Ld. AR further submits that ld. Addl. CIT granted common approval for various Assessment Years from 2013-14 to 2019-20 in terms of letter ... dated 20.04.2021. He submits that from the perusal of the same it could be seen that approval granted by the Id. Adl. CIT was mechanical approval and separate approval for each Assessment Year was not given rather approval was given by a single order for various assessment years. The letter

Sunil Jindal, Faridabad Haryana vs. Deputy Commissioner of Income Tax, Faridabad, Haryana

In the result, the appeal of the assessee is allowed

ITA 2524/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Jan 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 127Section 132Section 142(1)Section 143(2)Section 153ASection 250Section 68

assessee submitted that in the present case, approval was granted by ld. Addl. CIT, Central Range, Gurugram vide letter dated 20.04.2021 which is mechanical approval. Ld. AR further submits that ld. Addl. CIT granted common approval for various Assessment Years from 2013-14 to 2019-20 in terms of letter ... dated 20.04.2021. He submits that from the perusal of the same it could be seen that approval granted by the Id. Adl. CIT was mechanical approval and separate approval for each Assessment Year was not given rather approval was given by a single order for various assessment years. The letter

Sunil Jindal, Faridabad Haryana vs. Deputy Commissioner of Income Tax, Faridabad, Haryana

In the result, the appeal of the assessee is allowed

ITA 2523/DEL/2025[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 127Section 132Section 142(1)Section 143(2)Section 153ASection 250Section 68

assessee submitted that in the present case, approval was granted by ld. Addl. CIT, Central Range, Gurugram vide letter dated 20.04.2021 which is mechanical approval. Ld. AR further submits that ld. Addl. CIT granted common approval for various Assessment Years from 2013-14 to 2019-20 in terms of letter ... dated 20.04.2021. He submits that from the perusal of the same it could be seen that approval granted by the Id. Adl. CIT was mechanical approval and separate approval for each Assessment Year was not given rather approval was given by a single order for various assessment years. The letter

Sunil Jindal, Faridabad Haryana vs. Deputy Commissioner of Income Tax, Faridabad, Haryana

In the result, the appeal of the assessee is allowed

ITA 2522/DEL/2025[2014-15]Status: DisposedITAT Delhi21 Jan 2026AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 127Section 132Section 142(1)Section 143(2)Section 153ASection 250Section 68

assessee submitted that in the present case, approval was granted by ld. Addl. CIT, Central Range, Gurugram vide letter dated 20.04.2021 which is mechanical approval. Ld. AR further submits that ld. Addl. CIT granted common approval for various Assessment Years from 2013-14 to 2019-20 in terms of letter ... dated 20.04.2021. He submits that from the perusal of the same it could be seen that approval granted by the Id. Adl. CIT was mechanical approval and separate approval for each Assessment Year was not given rather approval was given by a single order for various assessment years. The letter

Sunil Jindal, Faridabad Haryana vs. Deputy Commissioner of Income Tax, Faridabad, Haryana

In the result, the appeal of the assessee is allowed

ITA 2521/DEL/2025[2013-14]Status: DisposedITAT Delhi21 Jan 2026AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 127Section 132Section 142(1)Section 143(2)Section 153ASection 250Section 68

assessee submitted that in the present case, approval was granted by ld. Addl. CIT, Central Range, Gurugram vide letter dated 20.04.2021 which is mechanical approval. Ld. AR further submits that ld. Addl. CIT granted common approval for various Assessment Years from 2013-14 to 2019-20 in terms of letter ... dated 20.04.2021. He submits that from the perusal of the same it could be seen that approval granted by the Id. Adl. CIT was mechanical approval and separate approval for each Assessment Year was not given rather approval was given by a single order for various assessment years. The letter

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

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

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

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

Pawan Singh Advocate, Haridwar vs. ITO, Roorkee

ITA 181/DDN/2025[2012-13]Status: DisposedITAT Dehradun14 Jan 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman(Through Video Conferencing)

Section 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

Pawan Singh Advocate, Haridwar vs. ITO, Roorkee

ITA 180/DDN/2025[2011-12]Status: DisposedITAT Dehradun14 Jan 2026AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman(Through Video Conferencing)

Section 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

Pawan Singh Advocate, Haridwar vs. CIT(A)& I.to., Roorkee

ITA 178/DDN/2025[2010-11]Status: DisposedITAT Dehradun14 Jan 2026AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman(Through Video Conferencing)

Section 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