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“speaking order”

Natural JusticeReasoned OrderReasoned Order6,856 judgments

The decision most relied on for speaking order is GKN Driveshafts (India) Ltd. v. ITO (259 ITR 19), cited in 1,349 judgments on BharatTax.

Leading authorities on speaking order

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

Kunhayammed v. State of Kerala
245 ITR 360 · 2000 · Supreme Court
361
citing judgments

An order refusing special leave to appeal to the Supreme Court, whether speaking or non-speaking, does not attract the doctrine of merger, meaning the order under challenge is not substituted.

M/s Sahara India (Farms) v. CIT & Anr.
300 ITR 403 · 2008 · Supreme Court
268
citing judgments

Administrative orders must be consistent with the rules of natural justice.

Kapurchand Shrimal v. CIT
131 ITR 451 · 1981 · Supreme Court
143
citing judgments

Appellate authorities in income-tax proceedings have the jurisdiction and duty to correct all errors of lower authorities. They must remit matters for proper or fresh adjudication and issue appropriate directions to ensure substantial justice, unless expressly forbidden by statute.

Bayer Material Science Pvt. Ltd. v. DCIT
382 ITR 333 · 2016 · High Court
89
citing judgments

Reassessment orders under Section 147/148 are without jurisdiction and invalid if the Assessing Officer fails to dispose of the assessee's objections to the reopening of assessment through a speaking order, as mandated by the GKN Driveshafts procedure.

Kunhayammed and Others v. State of Kerala
119 STC 505 · Reported
68
citing judgments

A Supreme Court speaking order dismissing a Special Leave Petition (SLP) has two implications: the statement of law contained therein constitutes a declaration of law under Article 141 of the Constitution, and its findings bind the parties and lower authorities.

PCIT v. Tupperware India Pvt. Ltd.
236 Taxmann 494 · 2016 · High Court
58
citing judgments

The incomplete disposal of an assessee's objections by the Assessing Officer makes the reassessment proceedings invalid. The Assessing Officer must dispose of the objections by a speaking order.

Home Finders Housing Ltd. v. ITO
404 ITR 611 · 2018 · High Court
56
citing judgments

Non-compliance with the GKN Driveshafts procedure, specifically not passing a speaking order on objections to reassessment before completing the assessment, is a curable procedural irregularity and does not nullify the assessment, particularly if the assessee did not request a speaking order.

Judgments citing speaking order

Rajendra Shakharam Badgujar, Ahmedabad vs. The ITO, Ward-5(3)(2), Ahmedabad

In the result, the appeal is allowed for statistical purposes

ITA 1087/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2020-21

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2020-21 Mr.Rajendra Shakharam Badgujar The Ito, Ward-5(3)(2) 42, Jay Raghunath Society Vs. Vejalpur Priya Cinema Road Ahmedabad. Krushnanagar Saijpur Ahmedabad 382 346. Pan : Afupb 1181 J (Applicant) (Responent)

For Appellant: Shri Ritesh Shah, AR
Section 139(4)Section 142(1)Section 143(2)Section 143(3)Section 249(2)Section 249(3)Section 250Section 56(2)(x)Section 69

Income-tax Rules, 1962, grant reasonable opportunity of being heard to the assessee, and decide the appeal afresh on merits by a speaking order. 8. In the result, the appeal is allowed for statistical purposes. Order pronounced in the Court on 12th August, 2025 at Ahmedabad. (SUCHITRA R. KAMBLE) ACCOUNTANT

Shree Aath Paragana Gurjar Prajapati Samaj Trust, Ahmedabad vs. CIT(Exemption), Ahmedabad, Vejalpur

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2025/AHD/2024[N.A.]Status: DisposedITAT Ahmedabad12 Aug 2025

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : - Shree Aath Paragana Gurjar Prajapati The Cit(Exemption) Samaj Trust Vs. Vejalpur Prajapati Bhavan Chatrala Ahmedabad. Sola Railway Over Bridge Naittar Chede, Sola Ghatlodia. Pan : Abfts 9086 E (Applicant) (Responent) : Assessee By Shri Prakash D. Shah & Shri Saiyam Shah, Ar : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/08/2025

Section 12ASection 12A(1)(ac)

trust for the relevant years, assess whether the trust has genuinely engaged in charitable activities without religious or caste-based exclusion, and pass a speaking order after granting due opportunity of hearing to the assessee. 5.8 In view of the foregoing discussion and respectfully following the judicial precedents relied upon

Jayvanti Janardan Bhanuskar, Raigad vs. ACIT, Circle-Panvel, Panvel

In the result, the appeal filed by the assessee is allowed for statistical

ITA 890/PUN/2025[2013-14]Status: DisposedITAT Pune12 Aug 2025AY 2013-14
For Appellant: Department byFor Respondent: Date of hearing
Section 271(1)(b)Section 271(1)(c)

aside the order of the Ld. CIT(A)/NFAC and restore the matter back to his file for adjudication afresh and pass speaking order on merits as per fact and law after allowing one final opportunity of being heard to the assessee. The assessee is also hereby directed to provide

Ganesh Agro Steel Industries, Nashik vs. The ACIT, Circle-1, Nashik

In the result, the appeal filed by the assessee is allowed for statistical

ITA 777/PUN/2025[2016-17]Status: DisposedITAT Pune12 Aug 2025AY 2016-17
For Appellant: Shri Sanket M JoshiFor Respondent: Shri Ramnath P Murkunde
Section 131Section 132Section 147Section 148Section 153C

appeal on ex-parte basis was not justified. 2] The learned CIT(A) erred in dismissing the appeal in limine without passing any speaking order on merits adjudicating the various grounds of appeal, which were supported by the statement of facts and replies filed before A.O. which were reproduced ... aside the order of the Ld. CIT(A)/NFAC and restore the matter back to his file for adjudication afresh and pass speaking order on merits as per fact and law after allowing one final opportunity of being heard to the assessee. The assessee is also hereby directed to provide

Shamrao Gopal Benake, Pune vs. ITO Ward 1(1), Pune

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1036/PUN/2025[2018-19]Status: DisposedITAT Pune12 Aug 2025AY 2018-19

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Respondent: Shri Akhilesh Srivastva
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

principles of natural justice. Accordingly, we hold that Ld. CIT(A)/NFAC was duty bound to decide each and every ground separately by a speaking order, and specifically when legal grounds against the validity of notice and reassessment are raised, it was compulsory for Ld. CIT(A)/NFAC to decide

Debdas Ghosh, Hooghly vs. ITO, Ward 24(1), Hooghly

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1062/KOL/2025[2020-2021]Status: DisposedITAT Kolkata12 Aug 2025AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 155(15)Section 250Section 56(2)(x)

remit the matter back to the Ld. CIT(A) for disposal of the grounds taken by the assessee on merit, by passing a speaking order as the valuation report was received and apparently no amendment had been done by the Ld. AO. Needless to say, the assessee shall be given

Sahyog Vanijya Limited, Kolkata vs. I.T.O., Ward-11(4), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1995/KOL/2024[2012-13]Status: DisposedITAT Kolkata12 Aug 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.1995/Kol/2024 Assessment Year: 2012-13 Sahyog Vanijya Pvt. Ltd.………………..……..…………………....Appellant 83, Shivam Apartments, S C Road, Barat Lake Town, Kol, W.B – 700069. [Pan: Aamcs5398C] Vs. Ito, Ward-11(4), Kolkata……………....…..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Smt. Sima Das Biswas, Jcit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 12, 2025 Date Of Pronouncing The Order : August 12,2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Dated 25.05.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2012–13. 2. At The Outset, The Registry Informed That There Is A Delay Of 428 Days In Filing The Instant Appeal. The Assessee Has Filed Application For Condonation Of Such Delay Citing Valid & Proper Reasons. After Considering The Averments Made In The Application, We Condone The Delay In The Appeal. 3. Brief Facts Of The Case Are That The Assessee Has Filed Return Of Income For The Assessment Year 2012-13 Declaring Total Loss Of Rs.591/- . On Information Received From Ito, (Inv.), Unit-1, Kolkata That The

Section 133(6)Section 143(2)Section 147Section 148Section 250Section 69A

when asked for without any fail and in case, the assessee failed to appear in remand proceedings, the ld. CIT(A) may pass a speaking order in accordance with law on the basis of materials available on record. 8. In terms of the above, the appeal of the assessee

Jesmajo Industrial Fabrications Karnataka Private Limited, Bangalore vs. DCIT, Circle 4(3)(1), Bangalore

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 953/BANG/2025[2018-19]Status: DisposedITAT Bangalore12 Aug 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2018-19

For Appellant: Shri Prasanna N Urala, AdvocateFor Respondent: Shri Balusamy N, JCIT (DR)
Section 250(6)

Bench. 6. We have heard both parties and perused the materials on record. We observe that the learned CIT(A) has not passed a speaking order. The order lacks proper reasoning and does not deal with the grounds raised by the assessee. As per section 250(6) of the Income ... mandatory for the learned CIT(A) to dispose of an appeal by a . Page 3 of 4 speaking order, stating the points for determination and the reasons for the decision. This legal requirement has not been complied with in the present case. 6.1 Furthermore, considering the submissions made

Nathoo Lalji Charity Trust, Mumbai vs. Income Tax Officer, Exem. Ward 2(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 3925/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Aug 2025AY 2019-20

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Satyaprakash R.Singh, CIT DR
Section 11Section 115BSection 143(3)

Accordingly, prayer made by the Ld. Counsel is accepted and the matter is remitted back to the file of Ld. AO to pass speaking order on the merits of the case. Thus, grounds raised by the assessee are allowed for statistical purposes. In the result, appeal of the assessee

Nathoo Lalji Charity Trust, Mumbai vs. Income Tax Officer, Exem. Ward 2(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 3924/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Satyaprakash R.Singh, CIT DR
Section 11Section 115BSection 143(3)

Accordingly, prayer made by the Ld. Counsel is accepted and the matter is remitted back to the file of Ld. AO to pass speaking order on the merits of the case. Thus, grounds raised by the assessee are allowed for statistical purposes. In the result, appeal of the assessee

Nathoo Lalji Charity Trust, Mumbai vs. Income Tax Officer, Exem. Ward 2(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 3923/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Satyaprakash R.Singh, CIT DR
Section 11Section 115BSection 143(3)

Accordingly, prayer made by the Ld. Counsel is accepted and the matter is remitted back to the file of Ld. AO to pass speaking order on the merits of the case. Thus, grounds raised by the assessee are allowed for statistical purposes. In the result, appeal of the assessee

Nathoo Lalji Charity Trust, Mumbai vs. Income Tax Officer, Exem. Ward 2(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 3907/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Aug 2025AY 2019-20

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Satyaprakash R.Singh, CIT DR
Section 11Section 115BSection 143(3)

Accordingly, prayer made by the Ld. Counsel is accepted and the matter is remitted back to the file of Ld. AO to pass speaking order on the merits of the case. Thus, grounds raised by the assessee are allowed for statistical purposes. In the result, appeal of the assessee

M/S. India Exposition Mart Ltd., New Delhi vs. DCIT, New Delhi

Appeal of the Assessee stands allowed

ITA 1079/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Aug 2025AY 2009-10

Bench: Shri Mahavir Singhshri Kuldip Singh & Shri Anadee Nath Misshra, Accountnat Member Shri Vikas Awasthy & Shri Brajesh Kumar Singh

For Appellant: Shri A. K. Khanna, C. A./NoneFor Respondent: Shri M.S. Nethrapal, CIT-DR
Section 139(1)Section 147Section 148

assessee's representative attended and submitted its reply vide which he just (reiterated its objection filed which were duly disposed off by passing a speaking order.) 2.3 The assessee's arguments have been considered but the same are not acceptable. Since, the written off of capital work in progress

Siva Sundari Narisikshasram and Ante Natal Clinic, Silchar vs. ITO(Exemption), Ward-2(3), Guwahati

Appeal is allowed for statistical purposes

ITA 78/GTY/2025[2021-22]Status: DisposedITAT Guwahati11 Aug 2025AY 2021-22

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 11Section 12A(1)Section 12A(1)(ac)Section 143(1)Section 250Section 250(6)

also gone through the records before us. It is seen that it was the primary responsibility of the first appellate authority to pass a speaking order as envisaged under Section 250(6) of the Act. However, it is appreciated that the first appellate authority did not have the benefit

Kanaiyalal Labhubhai Narola, Surat vs. The Asstt. Commissioner of Income Tax, Circle-3, (2), Surat

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

ITA 816/SRT/2023[2014-15]Status: DisposedITAT Surat11 Aug 2025AY 2014-15

Bench: Ms Suchitra Raghunath Kamble & Shri Buayananda Pruseth

Section 131Section 132Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

assessment. The addition was also made on appreciation of the facts and materials on record. The CIT(A) has also passed a detailed and speaking order confirming the action of AO. Hence, the order of CIT(A) may be upheld. 7. We have heard both the parties and perused

Income Tax Officer, Kurukshetra vs. Jasvir Singh, Village Diwana Tehsil Pehowa

In the result, appeal of the Revenue is dismissed

ITA 665/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh11 Aug 2025AY 2013-14

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 665/Chd/2023 "नधा"रण वष" / Assessment Year : 2013-14 Ito, Jasvir Singh, Kurukshetra बनाम Village Diwana Tehsil Pehowa, Vs. Distt. Kurukshetra 136128 "थायी लेखा सं./Pan No: Cnqps4895G अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 26.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 12.09.2023 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Shri Manav Bansal, CIT DR
Section 40A(3)

ITAT because the CIT (A) had not considered the submission of the appellant and confirmed the addition by passing a non-speaking order. The main contention of the appellant are as under: -  As Para 3.1 and 3.2 of the order, the AO has confirmed the genuineness of the purchases

Mohansundaram Jayasuja, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 959/CHNY/2025[2020-21]Status: DisposedITAT Chennai11 Aug 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunatha

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT
Section 147Section 148Section 263Section 263(1)(i)

with its source by issuing a notice. The assessee had duly submitted he details as called for and hence the AO had passed a speaking order incorporating he details submitted and thereby accepting the returned income in the order passed u/s.147 r.w.s. 143(3) of the Act dated 23.07.2021. Therefore ... Therefore, the Ld. AR argued that there is no error in the order of the Assessing Officer, since the Assessing Officer has passed a speaking order, after making the enquiry of the impugned issues. Hence, the Ld. AR submitted that, there is 25+: ITA, No:951 TO 959/Chny/2025 no reason

Mohansundaram Jayasuja, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 958/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Aug 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 951 To 953/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2013-14, 2014-15 & 2015-16 Subramaniam Mohan Sundaram, Pcit (Central)-2, 395, Oppanakara Street Vs. Chennai. Coimbatore – 641 001. [Pan: Aerpm-3937-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.: 954 & 955/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2017-18 & 2018-19 Subramaniam Mohan Sundaram Pcit (Central)-2, Legal Heir Of Late Smt. K.Lakshmi, Vs. Chennai. 395, Oppanakara Street Coimbatore – 641 001. [Pan: Aazpl-6816-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.: 956 To 959/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2015-16, 2016-17, 2018-19 & 2020-21 Mohansundaram Jayasuja, Pcit (Central)-2, 395, Oppanakara Street Vs. Chennai. Coimbatore – 641 001. [Pan: Aiypj-4331-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT
Section 147Section 148Section 263Section 263(1)(i)

with its source by issuing a notice. The assessee had duly submitted the details as called for and hence the AO had passed a speaking order incorporating the details submitted and thereby accepting the returned income in the order passed u/s.147 r.w.s. 143(3) of the Act dated 23.07.2021. Therefore ... Therefore, the Ld. AR argued that there is no error in the order of the Assessing Officer, since the Assessing Officer has passed a speaking order, after making the enquiry of the impugned issues. Hence, the Ld. AR submitted that, there is :-5-: ITA. No:951 TO 959/Chny/2025 no reason

Mohansundaram Jayasuja, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 957/CHNY/2025[2016-17]Status: DisposedITAT Chennai11 Aug 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 951 To 953/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2013-14, 2014-15 & 2015-16 Subramaniam Mohan Sundaram, Pcit (Central)-2, 395, Oppanakara Street Vs. Chennai. Coimbatore – 641 001. [Pan: Aerpm-3937-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.: 954 & 955/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2017-18 & 2018-19 Subramaniam Mohan Sundaram Pcit (Central)-2, Legal Heir Of Late Smt. K.Lakshmi, Vs. Chennai. 395, Oppanakara Street Coimbatore – 641 001. [Pan: Aazpl-6816-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.: 956 To 959/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2015-16, 2016-17, 2018-19 & 2020-21 Mohansundaram Jayasuja, Pcit (Central)-2, 395, Oppanakara Street Vs. Chennai. Coimbatore – 641 001. [Pan: Aiypj-4331-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT
Section 147Section 148Section 263Section 263(1)(i)

with its source by issuing a notice. The assessee had duly submitted the details as called for and hence the AO had passed a speaking order incorporating the details submitted and thereby accepting the returned income in the order passed u/s.147 r.w.s. 143(3) of the Act dated 23.07.2021. Therefore ... Therefore, the Ld. AR argued that there is no error in the order of the Assessing Officer, since the Assessing Officer has passed a speaking order, after making the enquiry of the impugned issues. Hence, the Ld. AR submitted that, there is :-5-: ITA. No:951 TO 959/Chny/2025 no reason

Mohansundaram Jayasuja, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 956/CHNY/2025[2015-16]Status: DisposedITAT Chennai11 Aug 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 951 To 953/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2013-14, 2014-15 & 2015-16 Subramaniam Mohan Sundaram, Pcit (Central)-2, 395, Oppanakara Street Vs. Chennai. Coimbatore – 641 001. [Pan: Aerpm-3937-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.: 954 & 955/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2017-18 & 2018-19 Subramaniam Mohan Sundaram Pcit (Central)-2, Legal Heir Of Late Smt. K.Lakshmi, Vs. Chennai. 395, Oppanakara Street Coimbatore – 641 001. [Pan: Aazpl-6816-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.: 956 To 959/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2015-16, 2016-17, 2018-19 & 2020-21 Mohansundaram Jayasuja, Pcit (Central)-2, 395, Oppanakara Street Vs. Chennai. Coimbatore – 641 001. [Pan: Aiypj-4331-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT
Section 147Section 148Section 263Section 263(1)(i)

with its source by issuing a notice. The assessee had duly submitted the details as called for and hence the AO had passed a speaking order incorporating the details submitted and thereby accepting the returned income in the order passed u/s.147 r.w.s. 143(3) of the Act dated 23.07.2021. Therefore ... Therefore, the Ld. AR argued that there is no error in the order of the Assessing Officer, since the Assessing Officer has passed a speaking order, after making the enquiry of the impugned issues. Hence, the Ld. AR submitted that, there is :-5-: ITA. No:951 TO 959/Chny/2025 no reason