Mechanical approval under Section 153D vitiated the assessment, and no substantial question of law arose in the revenue's appeal.

Mechanical approval under Section 153D of the Income-tax Act, granted without application of mind, vitiated the assessment; the defect was not cured by Section 292B. The Delhi HC relied on its earlier view sustaining annulment on the same basis and treated the Tribunal's finding as factual. On that footing, the revenue's challenge did not raise any substantial question of law, so the appeal was not entertained and was closed.

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Issues: Whether any substantial question of law arose in the revenue's appeal challenging the Tribunal's view that the assessment was vitiated for want of valid approval under Section 153D of the Income-tax Act, 1961.

Analysis: The appeal was examined in the light of the Tribunal's factual finding that the approving authority had granted approval mechanically and without application of mind. The Court also noted its earlier decision sustaining the annulment of the assessment order on the same basis and held that the defect was not a curable irregularity under Section 292B of the Income-tax Act, 1961. In that backdrop, the controversy did not give rise to any substantial question of law.

Conclusion: No substantial question of law arose for consideration. The revenue's challenge was not entertained and the appeal stood closed.

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