Union of India v. M.L. Capoor

2 SCC 836Reported decision1973#2811 most cited

What is Union of India v. M.L. Capoor authority for?

An authority's reasons for a decision must be specific and correlate the facts on record with the conclusion reached; mechanical or "rubber-stamp" reasons are insufficient.

42

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2026.

Also referred to as

Union of India v. M.L. Capoor · M.L. Capoor · mechanical reasons · rubber stamp reasons · reasons for decision · administrative authority reasons · Section 148 reasons · Section 151 sanction · correlated facts · natural justice principle · reasoned order.

Sections most often in play

Section 143(3)Section 148Section 151Section 153ASection 153DSection 147Section 132Section 133A

Issues it is cited on

principal chief commissioner of income-taxsection 271aab(1a)section 144basection 151(2)section 158bgsection 142(2a)section 271aabsection 271aac(1)section 153bsection 158section 158bsection 271aac

Judgments citing Union of India v. M.L. Capoor

SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

ITA 220/DDN/2025[2011-12]Status: DisposedITAT Dehradun18 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

…1 ITA Nos. 218, 219 & 220/DDN/2025 Society for Advancement in Education IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH, DEHRADUN BEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA No. 219/DDN/2025 (A.Y. 2010-11) Society for Advancement in Vs Income Tax Officer, Education. 17-A, Chaman Estate, Exemption Ward, Aaykar Near Hotel Sky Touch, Bhawan 13A, Subhash Road, Mussorie, Uttarakhand Dehradun, Uttarakhand PAN: AACAS5234K Appellant Respondent Assessee by Sh. Rajeev Shaini, CA Revenue by Sh. Amar Pal Singh, Sr. DR Date of Hearing 09/02/2026 Date of Pronouncement 18/02/2…

SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION WORD DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

ITA 219/DDN/2025[2010-11]Status: DisposedITAT Dehradun18 Feb 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

…1 ITA Nos. 218, 219 & 220/DDN/2025 Society for Advancement in Education IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH, DEHRADUN BEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA No. 219/DDN/2025 (A.Y. 2010-11) Society for Advancement in Vs Income Tax Officer, Education. 17-A, Chaman Estate, Exemption Ward, Aaykar Near Hotel Sky Touch, Bhawan 13A, Subhash Road, Mussorie, Uttarakhand Dehradun, Uttarakhand PAN: AACAS5234K Appellant Respondent Assessee by Sh. Rajeev Shaini, CA Revenue by Sh. Amar Pal Singh, Sr. DR Date of Hearing 09/02/2026 Date of Pronouncement 18/02/2…

SOCIETY FOR ADVANCEMENT IN EDUCATION,MUSSOORIE vs. ITO EXEMPTION WORD DEHRADUN, DEHRADUN

In the result, appeals of the assessee are allowed

ITA 218/DDN/2025[2009-10]Status: DisposedITAT Dehradun18 Feb 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

…1 ITA Nos. 218, 219 & 220/DDN/2025 Society for Advancement in Education IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN BENCH, DEHRADUN BEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA No. 219/DDN/2025 (A.Y. 2010-11) Society for Advancement in Vs Income Tax Officer, Education. 17-A, Chaman Estate, Exemption Ward, Aaykar Near Hotel Sky Touch, Bhawan 13A, Subhash Road, Mussorie, Uttarakhand Dehradun, Uttarakhand PAN: AACAS5234K Appellant Respondent Assessee by Sh. Rajeev Shaini, CA Revenue by Sh. Amar Pal Singh, Sr. DR Date of Hearing 09/02/2026 Date of Pronouncement 18/02/2…

PR COMMISSIONER OF INCOME TAX CENTRAL 2 vs. M/S. BELIEVE CONSTRUCTIONS P. LTD

ITA/555/2025HC Delhi29 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153DSection 260A

…ITA 555/2025 Page 1 of 12 $~83 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 29.10.2025 + ITA 555/2025 PR COMMISSIONER OF INCOME TAX CENTRAL 2 .....Appellant Through: Mr. Indruaj Singh Rai, SSC, Mr.Sanjeev Menon, Mr. Rahul Singh, JSCs and Mr. Gaurav Kumar, Advocates versus M/S. BELIEVE CONSTRUCTIONS P. LTD .....Respondent…

PRINCIPAL COMMISSIONER OF INCOME TAX-7 vs. M/S SHIVGANESH BUILDERS PVT. LTD

ITA/550/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ITA 536/2025 & Connected Appeal Page 1 of 13 $~66,69,70,72,74, 79 & 80 (seven cases) * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 28.10.2025 (66) + ITA 536/2025 PRINCIPAL COMMISSIONER OF INCOME TAX-7 .....Appellant versus M/S SHIVGORI BUILDERS PVT .....Respondent (69) + ITA 539/2025 PR. COMMISSIONER OF INCOME TAX,…

PRINCIPAL COMMISSIONER OF INCOME TAX-7 vs. M/S SHINE STAR BUILDCON PVT. LTD

ITA/549/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ITA 536/2025 & Connected Appeal Page 1 of 13 $~66,69,70,72,74, 79 & 80 (seven cases) * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 28.10.2025 (66) + ITA 536/2025 PRINCIPAL COMMISSIONER OF INCOME TAX-7 .....Appellant versus M/S SHIVGORI BUILDERS PVT .....Respondent (69) + ITA 539/2025 PR. COMMISSIONER OF INCOME TAX,…

PR. COMMISSIONER OF INCOME TAX-1 vs. M/S. BELIEVE CONSTRUCTIONS P. LTD

ITA/542/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ITA 536/2025 & Connected Appeal Page 1 of 13 $~66,69,70,72,74, 79 & 80 (seven cases) * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 28.10.2025 (66) + ITA 536/2025 PRINCIPAL COMMISSIONER OF INCOME TAX-7 .....Appellant versus M/S SHIVGORI BUILDERS PVT .....Respondent (69) + ITA 539/2025 PR. COMMISSIONER OF INCOME TAX,…

PR. COMMISSIONER OF INCOME TAX, I vs. M/S. BHUDEVA ESTATES P. LTD

ITA/539/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ITA 536/2025 & Connected Appeal Page 1 of 13 $~66,69,70,72,74, 79 & 80 (seven cases) * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 28.10.2025 (66) + ITA 536/2025 PRINCIPAL COMMISSIONER OF INCOME TAX-7 .....Appellant versus M/S SHIVGORI BUILDERS PVT .....Respondent (69) + ITA 539/2025 PR. COMMISSIONER OF INCOME TAX,…

PRRINCIPAL COMMISSIONER OF INCOME TAX-7 vs. M/S SHINE STAR BUILDCON PVT. LTD

ITA/540/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ITA 536/2025 & Connected Appeal Page 1 of 13 $~66,69,70,72,74, 79 & 80 (seven cases) * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 28.10.2025 (66) + ITA 536/2025 PRINCIPAL COMMISSIONER OF INCOME TAX-7 .....Appellant versus M/S SHIVGORI BUILDERS PVT .....Respondent (69) + ITA 539/2025 PR. COMMISSIONER OF INCOME TAX,…

PR. COMMISSIONER OF INCOME TAX-4 vs. SH. GOBIND KUMAR GOYAL

ITA/544/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ITA 536/2025 & Connected Appeal Page 1 of 13 $~66,69,70,72,74, 79 & 80 (seven cases) * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 28.10.2025 (66) + ITA 536/2025 PRINCIPAL COMMISSIONER OF INCOME TAX-7 .....Appellant versus M/S SHIVGORI BUILDERS PVT .....Respondent (69) + ITA 539/2025 PR. COMMISSIONER OF INCOME TAX,…

PRINCIPAL COMMISSIONER OF INCOME TAX-7 vs. M/S SHIVGORI BUILDERS PVT

ITA/536/2025HC Delhi28 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 153DSection 260A

…ITA 536/2025 & Connected Appeal Page 1 of 13 $~66,69,70,72,74, 79 & 80 (seven cases) * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision : 28.10.2025 (66) + ITA 536/2025 PRINCIPAL COMMISSIONER OF INCOME TAX-7 .....Appellant versus M/S SHIVGORI BUILDERS PVT .....Respondent (69) + ITA 539/2025 PR. COMMISSIONER OF INCOME TAX,…

ACIT, CC- 15, NEW DELHI vs. SALONI NARANG, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 1496/DEL/2018[2012-13]Status: DisposedITAT Delhi27 Oct 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2012-13] Asst. Commissioner Of Income Saloni Narang, Tax, Central Circle-15, 5, Dr. G.G. Narang Marg, Room No.353, E-2, Ara Vs Cavalary Lane, Centre, Jhandewalan Ext. Delhi-110007 New Delhi-110055 Pan-Aafpn2692C Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv. & Shri Somil Agarwal, Adv. Revenue By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 27.10.2025

Section 132Section 143(3)Section 153Section 153ASection 153DSection 69A

…conclusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under: "27.... We find considerable force in the submission made on behalf of the respondents that the 'rubber stamp' reason given mechanically for the supersession of each officer does not amount to 'reasons for the proposed supersession'. The most that could be said for the stock reason is that it i…

PR. COMMISSIONER OF INCOME TAX-1 vs. ASHUTOSH DEVELOPERS P. LTD

Appeals are dismissed, as no substantial question of law arises

ITA/522/2025HC Delhi15 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153D

…clusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under: “27.. .. We find considerable force in the submission made on behalf of the respondents that the ‘rubber stamp’ reason given Signed By:PRAMOD KUMAR VATS Signing Date:18.10.2025 14:52:11 Signature Not Verified ITA 522/2025 and connected matters…

PRINCIPAL COMMISSIONER OF INCOME TAX-7 vs. M/S SHIVGORI BUILDERS PVT. LTD

Appeals are dismissed, as no substantial question of law arises

ITA/523/2025HC Delhi15 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153D

…clusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under: “27.. .. We find considerable force in the submission made on behalf of the respondents that the ‘rubber stamp’ reason given Signed By:PRAMOD KUMAR VATS Signing Date:18.10.2025 14:52:11 Signature Not Verified ITA 522/2025 and connected matters…

PRINCIPAL COMMISSIONER OF INCOME TAX-1 vs. M/S MDLR RESORTS PVT. LTD

Appeals are dismissed, as no substantial question of law arises

ITA/530/2025HC Delhi15 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153D

…clusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under: “27.. .. We find considerable force in the submission made on behalf of the respondents that the ‘rubber stamp’ reason given Signed By:PRAMOD KUMAR VATS Signing Date:18.10.2025 14:52:11 Signature Not Verified ITA 522/2025 and connected matters…

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT, CENTRAL CIRCLE 4(1), MUMBAI

In the result, the appeals by the assessee for the

ITA 5631/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Dec 2024AY 2018-19

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

For Appellant: Shri Vinod Kumar BindalFor Respondent: Shri Kailash C. Kanojiya, CIT-DR
Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153DSection 250Section 270ASection 271(1)(c)Section 271A

…conclusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under:- "27.... We find considerable force in the submission made on behalf of the respondents that the 'rubber stamp' reason given mechanically for the supersession of each officer does not amount to 'reasons for the proposed supersession'. The most that could be said for the stock reason is that it…

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT-CENTRAL CIRCLE -4(1), MUMBAI

In the result, the appeals by the assessee for the assessment years

ITA 5630/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Dec 2024AY 2017-18

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

For Appellant: Shri Vinod Kumar BindalFor Respondent: Shri Kailash C. Kanojiya, CIT-DR
Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153DSection 250Section 270ASection 271(1)(c)Section 271A

…conclusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under: "27.. .. We find considerable force in the submission made on behalf of the respondents that the 'rubber stamp' reason given mechanically for the supersession of each officer does not amount to 'reasons for the proposed supersession'. The most that could be said for the stock reason is that it…

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT, CENTRAL CIRCLE -4(1), MUMBAI

In the result, the appeals by the assessee for the assessment years

ITA 5629/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Dec 2024AY 2017-18

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

For Appellant: Shri Vinod Kumar BindalFor Respondent: Shri Kailash C. Kanojiya, CIT-DR
Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153DSection 250Section 270ASection 271(1)(c)Section 271A

…conclusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under: "27.. .. We find considerable force in the submission made on behalf of the respondents that the 'rubber stamp' reason given mechanically for the supersession of each officer does not amount to 'reasons for the proposed supersession'. The most that could be said for the stock reason is that it…

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT, CENTRAL CIRCLE 4(1), MUMBAI

In the result, the appeals by the assessee for the

ITA 5628/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Dec 2024AY 2016-17

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

For Appellant: Shri Vinod Kumar BindalFor Respondent: Shri Kailash C. Kanojiya, CIT-DR
Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153DSection 250Section 270ASection 271(1)(c)Section 271A

…conclusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under:- "27.... We find considerable force in the submission made on behalf of the respondents that the 'rubber stamp' reason given mechanically for the supersession of each officer does not amount to 'reasons for the proposed supersession'. The most that could be said for the stock reason is that it…

NILESH SHAMJI BHARANI ,MUMBAI vs. DCIT, CENTRAL CIRCLE -4(1), MUMBAI

In the result, the appeals by the assessee for the

ITA 5627/MUM/2024[2014-15]Status: DisposedITAT Mumbai24 Dec 2024AY 2014-15

Bench: Shri Sandeep Singh Karhailsmt. Renu Jauhri

For Appellant: Shri Vinod Kumar BindalFor Respondent: Shri Kailash C. Kanojiya, CIT-DR
Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153DSection 250Section 270ASection 271(1)(c)Section 271A

…conclusion reached by an authority in respect of an issue, since they help in discerning the manner in which conclusion is reached by the concerned authority. Our opinion is fortified by the decision of the apex court in Union of India v. M.L. Capoor, (1973) 2 SCC 836 : AIR 1974 SC 87, 97 wherein it was observed as under:- "27.... We find considerable force in the submission made on behalf of the respondents that the 'rubber stamp' reason given mechanically for the supersession of each officer does not amount to 'reasons for the proposed supersession'. The most that could be said for the stock reason is that it…

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