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Facts
The Revenue appealed the CIT(A)'s order that quashed the assessment order. The CIT(A) had deleted an addition of ₹6,83,68,918/-. The Revenue argued that the CIT(A)'s order was not speaking and lacked clarity regarding the reopening of the assessment.
Held
The Tribunal observed that while the CIT(A) discussed various case laws regarding reopening, the closure of the order shifted focus to the addition without addressing the reopening issues adequately. The findings deleting the addition were without clear reasoning.
Key Issues
Whether the CIT(A) order was a speaking order with proper findings on both reopening and the addition made?
Sections Cited
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Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI
Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY
Department represented by Smt. Rinku Singh, CIT-DR Assessee represented by Sri Sanjay Chaterjee, A.R. Date of hearing 11/06/2025 Date of pronouncement 11/06/2025 O R D E R PER: BENCH 1. This is an appeal filed by the revenue against the order of the learned CIT(A), Jamshedpur in appeal No. CIT(A), Jamshedpur/10397/2017-18 dated 27/11/2019 for the A.Y. 2010-11.
Smt. Rinku Singh, ld. CIT-DR is represented on behalf of the revenue and Shri Sanjay Chatarjee, ld A.R. is represented on behalf of the assessee.
It was submitted by the ld. CIT-DR that the ld. CIT(A) has quashed the assessment order. It was a submission that the allegation is that the assessee has reopened on one ground and that the addition made on another ground. It was a prayer that the order of the ld. CIT(A) was not speaking and was not giving any clarity in regard to the reopening. It is a prayer that the issues may be restored to the file of ld. CIT(A) for passing a proper speaking order and giving a proper finding.