“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

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

ITA 177/DDN/2025[2009-10]Status: DisposedITAT Dehradun14 Jan 2026AY 2009-10

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

R.N. Khemka Enterprises (P) Ltd., Delhi vs. ITO, Ward- 20(3), New Delhi

In the result, assessee’s appeal is allowed

ITA 6016/DEL/2018[2007-08]Status: DisposedITAT Delhi14 Jan 2026AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklaassessment Year: 2007-08

Section 133(6)Section 139Section 143(3)Section 147Section 148Section 151

sustainable in the eyes of law. 11. We have further considered the judgment relied upon by the Ld. AR on the ground of mechanical approval specifically on the mere statement of “I am satisfied with the reasons, it is a fit case for the issue of a notice

Rakesh Divedi, Delhi vs. Income Tax Officer, Ward 43(6), Delhi

In the result, appeal of the Assessee is allowed

ITA 3290/DEL/2025[2009-10]Status: DisposedITAT Delhi09 Jan 2026AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwalrakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. Pan-Apcpd9179A (Appellant) (Respondent) Shri Pranshu Singhal, Ca Assessee By & Ms. Mansi Jain, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 09/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 07.03.2025 In Appeal No.40/10204/2018-19 Arising Out Of The Order Passed By The Income Tax Officer, Ward-40(3) U/S 143(3) Of The Act (‘The Act’ For Short) Dated 20.12.2016 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Proprietor Of M/S Triambkay Gauri Impex. The Information Was Received By The Ao From Investigation Wing That There Were Cash Deposits In The Bank Account Of The Assesse With Icici Bank, However, Income Of The Assessee & Gross Receipt Has Not Rakesh Divedi Vs. Income Tax Officer Commensurate With The Cash So Deposited, Therefore, After Recording The Reason U/S 147, Notice U/S 148 Was Issued On 31.03.2016 After Obtaining Statutory Approval From The Pcit. Thereafter, Assessment Was Completed Vide Order Dated 20.12.2016 Wherein Total Addition Of Rs. 5,20,88,345/- Was Made U/S 68 Of The Act For Cash Deposited In The Bank Accounts By Holding The Same As Unexplained Cash Credits. 3. Against The Said Order, Assessee Has Filed An Appeal Before Ld. Cit(A) Who Vide Impugned Order Has Partly Allowed The Appeal Of The Assessee & Directed The Ao To Make Addition Of Peak Credit Of The Total Deposits In The Bank Accounts.

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68

appeal No. 3 & 4 are with respect to the validity of reopening of the assessment as the approval given by ld. PCIT is mechanical approval and reasons recorded are vague and based on borrowed satisfaction. 10. Heard both the parties and perused the materials available on record. In the instant ... find that the Ld. PCIT has not applied his mind and given approval by observing “Yes, I am satisfied” which appears to be a mechanical approval given without referring to any material available before him. Therefore, we hold the said Rakesh Divedi vs. Income Tax Officer approval as mechanical approval

Assistant Commissioner of Income Tax, Central Circle-25 New Delhi, Delhi vs. Faridabad Presswell Pvt Ltd, Delhi

In the result, the appeal of the

ITA 2801/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2801/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Assistant Commissioner Of Faridabad Presswell Pvt. Ltd. Income Tax, Vs. 24, Ashoka Chamber, 5B, Central Circle-25, Room No.317, Rajindra Park, Pusa Road, 3Rd Floor, E-2, Ara Centre, New Delhi. Jhandewalan Extension, Pan No. Aaacfs815B Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 250

order dated 08.03.2024 (copy attached with this e-mail it can be observed that: (i) The respondent assessee had not taken any ground w.r.t. mechanical approval under section 153D of the Act (as stated in Additional Ground No.1) and therefore this ground was neither before the previous appellate authority

Singhal Fasteners Company Private Limited, New Delhi vs. ITO Ward - 23(4), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1992/DEL/2020[2006-07]Status: DisposedITAT Delhi09 Jan 2026AY 2006-07

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2006-07 Vs M/S Singhal Fasteners Company Ito Ward-8(4) New Delhi Private Limited 67-68 Rampuri Govind Puri Kalkaji New Delhi-19 Pan No. Aaacs1428H (Respondent) (Appellant)

Section 147Section 148

therefore following the decision of the Hon’ble Supreme Court and Coordinate Bench, we hold that the approval granted in this case is a mechanical approval and the re-assessment proceedings initiated based on such approval is bad in law. Therefore, we allowed the additional ground raised by the assessee

Neetal Relan, New Delhi vs. ACIT, Central Circle-14, New Delhi

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

ITA 3038/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 153CSection 250

ITAT Delhi in the case Dheeraj Chaudhary Vs. ACIT in ITA No. 6158/Del/2018 dt. 10.11.2025, to contend that in case of common and mechanical approval u/s 153D of the Act for various assessment years, the assessment is liable to be quashed. 11. On the other hand ... 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

Neetal Relan, New Delhi vs. ACIT, Central Circle-14, New Delhi

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

ITA 3037/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 153CSection 250

Bishnu Transport Company, Dhanbad vs. DCIT/ACIT, Circle-1, Dhanbad

In the result, the appeal of the assessee is allowed

ITA 401/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(3)Section 147Section 148Section 151Section 151oSection 68

copy of the approval order supplied to the assessee shows that approval was granted commonly for multiple assessees through a computer-generated format. Such mechanical approval vitiates the assumption of jurisdiction under section 147 of the Act. It was submitted that the additional ground goes to the root

Pankaj Jindal Contractor, Mansa vs. The Deputy Commissioner of Income Tax, Circle-I, Bathinda

In the result the appeal of the assessee is allowed

ITA 695/ASR/2024[2014-15]Status: DisposedITAT Amritsar05 Jan 2026AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 695/Asr/2024 Assessment Year: 2014-15 M/S Pankaj Jindal Contractor, Vs. Dcit-Circle-1, Near Vidya Bharti School, Bathinda. Mansa. [Pan:-Aajfp8008L] (Appellant) (Respondent) Appellant By Sh. Sudhir Sehgal, Adv. Respondent By Sh. Charan Dass, Sr. Dr

Section 139(1)Section 143(3)Section 147Section 148Section 148aSection 250Section 282Section 40A(3)Section 68

assessee, vide order u/s 250 of the Act dt. 17.10.2024, because the proceedings-initiated u/s 147/148 are void ab-initio as there was mechanical approval of the Pr. CIT with regard to reopening of the case u/s 148and, as such, proceedings u/s 148 are liable to be quashed in view ... appeal. At the onset the Ld. AR of the assessee withdrew grounds No 2 (disputing service of reassessment notice) and ground No 4 (alleging mechanical approval by PCIT) as not pressed. 6. The Ld. AR of the assesse has filed a paper book containing copies of audited accounts with schedules

Vikas Jain, Kanpur vs. ACIT-CC 2(1)(1), Kanpur

In the result, the appeal of the assessee is partly allowed

ITA 434/LKW/2024[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 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), Nfac On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Amit Kumar, DR

Section 143(1)Section 147Section 148Section 151Section 156Section 48Section 50C

file or not and on this ground, there was no lapse by the approving authority. Therefore, such approval could not be termed as mechanical approval as alleged by the assessee. It was also submitted that section 50C was a deeming provision, which was not concerned with the actual consideration received

Hardayal Milk Products Private Limited, Shikohabad vs. DCIT, Circle-2(2)(1), Firozabad

In the result, both the appeals filed by assessee are allowed

ITA 344/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

SPECIAL LEAVE PETITION (CIVIL) Diary No.55481/2024 order dated 02.01.2025) 14 | P a g e ITA No.344 & 343/Agr/2025 Invalidity of re-assessment proceedings, based on mechanical approval by learned PCIT u/s. 151: 3.0 In this context, the appellant submits that the requirement for sanction to issue notice ... However, there is no indication of independent examination, scrutiny, or satisfaction. Such a blanket endorsement is a classic case of mechanical approval, devoid of due consideration, particularly when the reasons recorded by the Assessing Officer too are based on mere information from Investigation Wing, Kolkata, without verifying the transactions

Hardayal Milk Products Private Limited, Shikohabad vs. DCIT, Circle-2(2)(1), Firozabad

In the result, both the appeals filed by assessee are allowed

ITA 343/AGR/2025[2013-14]Status: DisposedITAT Agra29 Dec 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(3)Section 145(3)Section 147Section 148Section 151Section 250Section 68

Sushil Kumari, Delhi vs. ITO (W) 36(1), Delhi

Appeal is allowed

ITA 7076/DEL/2025[2017-18]Status: DisposedITAT Delhi29 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18

Section 147Section 151

position, I hereby quote PCIT v. Goyanka Lime & Chemical Ltd. [2015] 64 taxmann.com 313 (SC) to quash the impugned assessment itself as such a mechanical approval exercise is not sustainable in law. Ordered accordingly. All other pleadings between the parties on merits stand rendered academic. 4. This assessee’s appeal

Murari Lal Through Legal Heir Savitri Devi, Faridabad vs. Income Tax Officer, Faridabad

Appeal is allowed

ITA 4003/DEL/2025[2014-15]Status: DisposedITAT Delhi24 Dec 2025AY 2014-15

Section 147Section 151

independent mind thereupon. 4. 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

Sanif Ahmed, Meerut vs. ITO, Ward 2(3), Meerut

Appeal is allowed

ITA 3995/DEL/2025[2012-13]Status: DisposedITAT Delhi23 Dec 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2012-13 Sanif Ahmed, Vs. Income Tax Officer, 70, Topchiwada, Kotwali, Ward-2(3), Meerut Meerut Pan: Bflpa1150E (Appellant) (Respondent) Assessee By None (Written Submission) Department By Shri Mahesh Kumar, Cit(Dr)

Section 147Section 151

Jakson Limited, Delhi vs. DCIT, CC-4, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 5014/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR

Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

quashed. (d) That on the facts and in the circumstances of the case, the approval taken by Ld. AO u/s 151 is mechanical approval as the same has been granted by PCIT/CIT instead of PCCIT/PDGIT/ CCIT/ DGIT. (e) That on the facts and in the circumstances of the case

ACIT, New Delhi vs. Jakson Limited, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 5010/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR

Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

ACIT, New Delhi vs. Jakson Limited, Delhi

In the result, the appeal of the assessee is allowed and both the appeals of revenue are dismissed

ITA 4987/DEL/2024[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Ms. Madhumita Roy & Mrs. Renu Jauhri

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Chandra Bhanu Mandal, SR. DR

Section 115JSection 147Section 15Section 250Section 37(1)Section 69CSection 80G

DCIT, Delhi vs. Sushil Goel, Delhi

In the result appeal of the revenue is dismissed

ITA 3490/DEL/2023[2020-21]Status: DisposedITAT Delhi22 Dec 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita No.3014/Del/2023 (Assessment Year 2020-21)

Section 1Section 115BSection 153Section 153ASection 250Section 69A

which order, approval was granted i.e. no reference of any draft assessment order was made in the approval letter and thus it is a mechanical approval granted without application of mind. Ld. AR submits that it appears that no draft assessment order was sent ITA Nos.3488/ & 3490Del/2023 Sushil Goel ... Revenue supports the order of AO and submits that approval was not granted on the same day and not 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 time

DCIT, Delhi vs. Sushil Goel, Delhi

In the result appeal of the revenue is dismissed

ITA 3488/DEL/2023[2019-20]Status: DisposedITAT Delhi22 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita No.3014/Del/2023 (Assessment Year 2020-21)

Section 1Section 115BSection 153Section 153ASection 250Section 69A