Rasiklal Ranchhodbhai\nPatel's v. CWT

121 ITR 219High Court1980#14763 most cited
6

judgments rely on this decision, according to BharatTax’s citation analysis of 346,713 Indian tax judgments — from 2024 to 2025.

Sections most often in play

Section 147Section 148Section 37(1)Section 115BBESection 131Section 133ASection 143(3)Section 250

Issues it is cited on

section 115beproximate nexussection 91preponderance of probabilityviolation of natural justicecreditworthiness of the creditoraddition under section 68section 148a(d)section 37(1)commissioner (appeals)section 37section 115bb

Judgments citing Rasiklal Ranchhodbhai\nPatel's v. CWT

ACIT, Circle-1, Nashik vs. Taparia Tools Limited, Nashik

In the result, both the appeal of the Revenue as well as Cross Objection of the assessee are allowed for statistical purposes as per the terms indicated above

ITA 1337/PUN/2025[2017-18]Status: DisposedITAT Pune10 Dec 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1337/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Amit BobdeFor Respondent: Shri Viral Shah
Section 142(1)Section 147Section 148Section 37(1)

…y on the part of the judicial or quasi-judicial authority to pass a reasoned order while exercising statutory jurisdiction. Reliance is also placed on the decision of Hon. Gujarat High Court in Rasiklal Ranchhodbhai Patel vs. Commissioner of Wealth-tax [1980] 121 ITR 219 (GUJ.) (Annexure-3) where in it has been held that : It is settled law that where an authority makes an order in exercise of a quasi-judicial function, it must record its reasons in support of the order it makes. Every quasi-judicial order must be supported by reasons. The rule requiring reasons to be given in support of an order is, like the pr…

Deputy Commissioner of Income Tax, Central Circle -5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue

ITA 4878/MUM/2023[2020-21]Status: DisposedITAT Mumbai27 May 2025AY 2020-21

Bench: Hon'Ble Shri Sandeep Gosain & Hon'Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…quasi-judicial authorities should always give reasons in support of their conclusions—Woohombers of India Ltd. v. Workers Union AIR 1973 SC 2758. Relying upon this decision of the Supreme Court, the Gujarat High Court in Rasiklal Ranchhodbhai Patel's V/s. CWT 121 ITR 219 (Guj) held that by passing such a cryptic order in a matter where he was required to exercise discretion and act in a quasi-judicial manner, the Commissioner had violated the principle of audi alterm partem. The order was struck down as only an apology of reasons had been given where substantial reasons were needed. Incorporation of reasons for a…

Deputy Commissioner of Income Tax, Central Circle -5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue stands dismissed

ITA 4872/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 May 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…quasi-judicial authorities should always give reasons in support of their conclusions—Woohombers of India Ltd. v. Workers Union AIR 1973 SC 2758. Relying upon this decision of the Supreme Court, the Gujarat High Court in Rasiklal Ranchhodbhai Patel's V/s. CWT 121 ITR 219 (Guj) held that by passing such a cryptic order in a matter where he was required to exercise discretion and act in a quasi-judicial manner, the Commissioner had violated the principle of audi alterm partem. The order was struck down as only an apology of reasons had been given where substantial reasons were needed. Incorporation of reasons for a…

Deputy Commissioner of Income Tax, Central Circle-5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue

ITA 4866/MUM/2023[2021-22]Status: DisposedITAT Mumbai27 May 2025AY 2021-22

Bench: Hon’Ble Shri Sandeep Gosain & Hon'Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…quasi-judicial authorities should always give reasons in support of their conclusions—Woohombers of India Ltd. v. Workers Union AIR 1973 SC 2758. Relying upon this decision of the Supreme Court, the Gujarat High Court in Rasiklal Ranchhodbhai Patel's V/s. CWT 121 ITR 219 (Guj) held that by passing such a cryptic order in a matter where he was required to exercise discretion and act in a quasi-judicial manner, the Commissioner had violated the principle of audi alterm partem. The order was struck down as only an apology of reasons had been given where substantial reasons were needed. Incorporation of reasons for a…

Deputy Commissioner of Income Tax, Central Circle- 5(2), Mumbai, Nariman Point vs. Agv Consultants, Borivali (E), Mumbai

In the result, all the appeals filed by the revenue stands dismissed

ITA 4865/MUM/2023[2018-19]Status: DisposedITAT Mumbai27 May 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 131Section 133ASection 250Section 68

…quasi-judicial authorities should always give reasons in support of their conclusions—Woohombers of India Ltd. v. Workers Union AIR 1973 SC 2758. Relying upon this decision of the Supreme Court, the Gujarat High Court in Rasiklal Ranchhodbhai Patel's V/s. CWT 121 ITR 219 (Guj) held that by passing such a cryptic order in a matter where he was required to exercise discretion and act in a quasi-judicial manner, the Commissioner had violated the principle of audi alterm partem. The order was struck down as only an apology of reasons had been given where substantial reasons were needed. Incorporation of reasons for a…

Shri Krishnaraj Buildhome Pvt Ltd, Jaipur vs. Income Tax Officer, Jaipur

ITA 753/JPR/2023[2014-15]Status: DisposedITAT Jaipur14 Feb 2024AY 2014-15
For Appellant: Sh. Mukesh Kumar Sharma (Adv.)For Respondent: Sh. Monisha Choudhary (Addl.CIT)
Section 143(3)Section 271(1)(c)Section 43CSection 50

…o give reasons is a safety-valve against arbitrary exercise of discretionary power. If such quasi-judicial authorities are permitted to render order without reason, apart from arbitrariness there might be potent danger. (6) Rasiklal Ranchhodbhai v. CWT [1980] 121 ITR 219 (Guj.), The Hon'ble Court struck down the order of the Commissioner by observing that passing a cryptic order without giving reasons violates the principles of natural justice. It was observed that reasons must be substantial and cogent. Additional Ground No.2 On the facts and in the circumstances of the case and in law, the learned CIT(A) has er…

Rasiklal Ranchhodbhai\nPatel's v. CWT (121 ITR 219) — Cited in 6 Judgments | BharatTax