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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

Mahendra Kumar Gupta HUF, Indore vs. ACIT Circle-2(1), Raipur

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 137/RPR/2025[2011-12]Status: HeardITAT Raipur17 Apr 2025AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.137/Rpr/2025 "नधा"रण वष" /Assessment Year: 2011-12 Mahendra Kumar Gupta Huf 404, Suraj Villa, 9/2, New Palasia, Indore (M.P)-452 001 Pan: Aaghm8528M .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-2(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं./Ita No.138/Rpr/2025 "नधा"रण वष" /Assessment Year: 2012-13 Mahendra Kumar Gupta 404, Suraj Villa, 9/2, New Palasia, Indore (M.P)-452 001 Pan: Adcpg7886K .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-2(1), Raipur (C.G.) ……""यथ" / Respondent : Mrs. Shelly Maheshwari, Ca Shri Ashish Goyal, Advocate Revenue By : Dr. Priyanka Patel, Sr. Dr

For Respondent: Mrs. Shelly Maheshwari, CA
Section 5

highest fact finding authority must be certain enough that the impugned order before it has been passed on merits and is a speaking order where the assessee has also complied during the process of litigation. In case, where the order of the Ld. CIT(Appeals) itself is ex-parte ... framework of the Act, Ld.CIT(Appeals) is the first appellate authority where an appeal by assessee it would be substantially decided through a speaking order by the Ld.CIT(Appeals). When this part is over and either party is aggrieved second appeal lies before the ITAT. Now if for every

Saraswati Shishu Vidya Mandir Parichalana Samiti, Puri vs. Commissioner-of-Income Tax(Exemption), Hyderabad

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

ITA 120/CTK/2025[2025-26]Status: DisposedITAT Cuttack17 Apr 2025AY 2025-26

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 12Section 80G

erred in law and on facts in rejecting the application for registration under Section 80G of the Income Tax Act 1961 without providing a speaking order, despite the appellant fulfilling all statutory requirements and submitting requisite documents. 2. That the Appellant is solely educational School has submitted it audit report

Odisha Eco Tourism Foundation Trust, Puri vs. Commissioner-of-Income Tax(Exemption), Hyderabad

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

ITA 119/CTK/2025[2025-26]Status: DisposedITAT Cuttack17 Apr 2025AY 2025-26

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 12Section 80G

erred in law and on facts in rejecting the application for registration under Section 80G of the Income Tax Act 1961 without providing a speaking order, despite the appellant fulfilling all statutory requirements and submitting requisite documents. 2. That the Ld. Commissioner of Income Tax (Exemptions) failed to appreciate that

Puri Rotary Charitable Trust, Puri vs. Commissioner-of-Income Tax(Exemption), Hyderabad

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

ITA 118/CTK/2025[2025-26]Status: DisposedITAT Cuttack17 Apr 2025AY 2025-26

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 12Section 80G

erred in law and on facts in rejecting the application for registration under Section 80G of the Income Tax Act 1961 without providing a speaking order, despite the appellant fulfilling all statutory requirements and submitting requisite documents. 2. That the Ld. Commissioner of Income Tax (Exemptions) failed to appreciate that

Bhakta Dasia Smruti Committee, Puri vs. Commissioner-of-Income Tax(Exemption), Hyderabad

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

ITA 117/CTK/2025[2025-26]Status: DisposedITAT Cuttack17 Apr 2025AY 2025-26

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 12Section 80G

erred in law and on facts in rejecting the application for registration under Section 80G of the Income Tax Act 1961 without providing a speaking order, despite the appellant fulfilling all statutory requirements and submitting requisite documents. 2. That the Ld. Commissioner of Income Tax (Exemptions) failed to appreciate that

Mahmad Atik Farukmiya Sheikh, Valsad vs. Income Tax Officer- Ward (5), Valsad

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

ITA 819/SRT/2024[2017-18]Status: DisposedITAT Surat17 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.819/Srt/2024 Assessment Year: (2017-18) (Physical Hearing) Mahmad Atik Farukmiya Sheikh, Vs. The Ito, Masjid Faliya Dehali, Dhagadmal, Ward – 5, Valsad - 396126 Valsad "थायीलेखासं./जीआइआरसं./Pan/Gir No: Duaps5433Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 12/02/2025 Date Of Pronouncement 17/04/2025

Section 115BSection 253(3)Section 69A

circumstances of the case as well as law on the subject, the learned CIT(A) has erred in dismissing the appeal without passing speaking order. 3. On the facts and circumstances of the case as well as law on the subject, the learned assessing officer has erred in making

Hariram Hospital, Alwar vs. PCIT, Alwar

In the result, the appeal of the assessee is allowed

ITA 1535/JPR/2024[2019-20]Status: DisposedITAT Jaipur17 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1535/JPR/2024 निर्धारणवर्ष / Assessment Year: 2019-20 Hariram Hospital Bye Pass Road Hariram Hospital Bhiwadi, Alwar – 310 019 (Raj) बनाम Vs. The Pr.CIT (Central) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAFFH 5746 M अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri Himanshu Goyal, CA राजस्व की ओरसे /Revenue by: Mrs. Alka Gautam, CIT-DR सुनवाई की तारीख / Da

For Appellant: Shri Himanshu Goyal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 263

That the objections raised by the assesse during the revision proceedings were not disposed of by the ld. PCIT through a reasoned or speaking order which is a procedural lapse and violates principles of natural justice. 3 HARIRAM HOSPITAL, ALWAR VS PCIT (CENTRAL), JAIPUR 4. That the ld PCIT erred

ACIT, Circlle-34, Kolkata vs. Subhas Kumar Kedia, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1677/KOL/2024[2016-17]Status: DisposedITAT Kolkata17 Apr 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri P.N.Barnwal, CIT-DR
Section 148Section 148ASection 149Section 151Section 246ASection 3Section 69A

while supporting the order passed by the ld. CIT(A) a that the order passed by the ld. CIT(A) is very reasoned and speaking order which is passed in consonance with the provisions of the Act. Ld. AR submitted that the notice u/s.148 of the old regime was issued

Mridula Healthcare (P) Ltd, New Delhi vs. ITO, Ward-17(4), New Delhi

In the result, assessee’s appeal is allowed for statistical purpose

ITA 63/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Apr 2025AY 2017-18
Section 115BSection 143(3)Section 68Section 69A

counsel for the assessee at the outset submitted that the ex parte order passed by the Ld. First Appellate Authority is not a speaking order as contemplated u/s 250(6) of the Act and rather simply has affirmed the action of Ld. AO, confirming the addition

E Ashwath Narayan, Bangalore vs. Income Tax Officer, Ward-3(3)(1), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 1920/BANG/2024[2015-16]Status: DisposedITAT Bangalore17 Apr 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Sri S. Satish, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 142(1)Section 144Section 147Section 148Section 148ASection 149(1)Section 250Section 69A

would have all the trappings of reasons recorded, objections raised by the assessee and disposal of such objections through the speaking order which is required to be enclosed with the notice u/s 148 of the Act. The High Court of Delhi in the case of Divya Capital ... exercise of jurisdiction to initiate reassessment proceedings under section 148 of the Act. In the present case the AO should have passed a speaking Order U/s 148A(d) of the Act before directly jumped into the issuing of the notice u/s 148 of the Act. The clause (d) of section

Avinash Awhad Legal Heir of Eknath Shivram, Mumbai vs. Income Tax Officer 28(1)(1), Mumbai

ITA 1063/MUM/2025[2011-12]Status: DisposedITAT Mumbai17 Apr 2025AY 2011-12

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Avinash Awhad (Legal Heir Of Ito Ward 28(1)(4) Eknath Awhad) Vashi Railway 102/Kukreja Crystal, Plot No. Vs. Station Building 79A, Sector 14, Koparkhairane Vashi, Navi Mumbai Navi Mumbai- 400 709 400709. Pan : Agapa3822C Appellant Respondent

For Appellant: Shri Manoj Kumar SinhaFor Respondent: Shri Shalin S. Divatia
Section 148Section 69A

file all necessary documents before the Ld. CIT(A) to establish his case and the Ld. CIT(A) is directed to pass a speaking order on merits after giving an effective opportunity to the appellant. 8. The appellant of appellant is allowed for statistical purposes. Order pronounced in the open

Thomas Cook India Limited (Sucessor of Travel Corpn (India) Limited), Mumbai vs. DCIT 3(3)(1), Mumbai

ITA 4068/MUM/2024[2016-17]Status: DisposedITAT Mumbai17 Apr 2025AY 2016-17

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Hemanshu JoshiFor Respondent: Shri Jayesh Chobisa
Section 32(1)Section 43(1)

appellant nor adjudicated why the cases-law relied on by appellant are not relevant/applicable. Since the order of Ld. CIT(A) is a non-speaking order and did not adjudicate the issues raised before him while passing the appellate order, it is decided by the Bench that the issues ... file of Ld. CIT(A) with a direction that all the grounds raised by appellant should be properly addressed and a speaking order should be passed after giving opportunity to the appellant. 5. The appeals of appellant are allowed for statistical purposes. Order pronounced in the open Court on 17/04/2025

Manoj Kumar Jain, Raipur vs. Income Tax Officer, Ward-1(2), Raipur

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

ITA 77/RPR/2025[2018-19]Status: DisposedITAT Raipur16 Apr 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.77/Rpr/2025 "नधा"रण वष" /Assessment Year : 2018-19 Manoj Kumar Jain M/S. Vidyashree Trading, Ghul Ghul, Tilda, Neora, Raipur (C.G.)-493 114 Pan: Achpj6480G .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Raipur (C.G) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(1)Section 143(1)(a)Section 250Section 36(1)(iii)

order. Accordingly, I am of the considered view that the order of the Ld.CIT(Appeals)/NFAC is bereft of facts and is not a speaking order, hence it is set-aside. In the interest of natural justice, the matter is restored to the file of the Ld.CIT(Appeals/NFAC for fresh ... adjudication. It is directed that the Ld. CIT(Appeals)/NFAC shall consider all the submissions of the assessee and come up with a speaking order in terms with Section 250(4) & (6) of the Act within three months from receipt of this order. 8. As per the above terms

Late Shanti Mohta, Raipur vs. Income Tax Officer Ward 2(1), Raipur

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

ITA 71/RPR/2025[2017-18]Status: DisposedITAT Raipur16 Apr 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.71/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Late Shanti Mohta 15/391, Jawahar Nagar, Ravigram S.O Chhattisgarh- 492 001 Pan: Aldpm6184F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-2(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Mahendra Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 5

highest fact finding authority must be certain enough that the impugned order before it has been passed on merits and is a speaking order where the assessee has also complied during the process of litigation. In case, where the order of the Ld. CIT(Appeals) itself is ex-parte ... framework of the Act, Ld.CIT(Appeals) is the first appellate authority where an appeal by assessee it would be substantially decided through a speaking order by the Ld.CIT(Appeals). When this part is over and either party is aggrieved second appeal lies before the ITAT. Now if for every

Kalyan Gas Agency, Raipur vs. Income Tax Officer, Ward-3(1), Raipur

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

ITA 62/RPR/2025[2017-18]Status: DisposedITAT Raipur16 Apr 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.62/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Kalyan Gas Agency 1, New Bus Stand, Pandri, Raipur (C.G.)-492 001 Pan: Aagfk4563Q .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 5

highest fact finding authority must be certain enough that the impugned order before it has been passed on merits and is a speaking order where the assessee has also complied during the process of litigation. In case, where the order of the Ld. CIT(Appeals) itself is ex-parte ... framework of the Act, Ld.CIT(Appeals) is the first appellate authority where an appeal by assessee it would be substantially decided through a speaking order by the Ld.CIT(Appeals). When this part is over and either party is aggrieved second appeal lies before the ITAT. Now if for every

Geeta Patel, Raipur vs. Income Tax Officer, Ward 3(1), Raipur

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

ITA 125/RPR/2025[2015-16]Status: DisposedITAT Raipur16 Apr 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.125/Rpr/2025 "नधा"रण वष" /Assessment Year : 2015-16 Geeta Patel House No.B-13, Sector-5, Devendra Nagar, Raipur (C.G.) Pan: Aeqpp8409Q .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Office, Ward-3(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250Section 250(6)Section 251(1)(a)Section 251(2)

Ward-3(1), Raipur authority must be certain enough that the impugned order before it has been passed on merits and is a speaking order where the assessee has also complied during the process of litigation. In case, where the order of the Ld. CIT(Appeals) itself is ex-parte ... framework of the Act, Ld.CIT(Appeals) is the first appellate authority where an appeal by assessee it would be substantially decided through a speaking order by the Ld.CIT(Appeals). When this part is over and either party is aggrieved second appeal lies before the ITAT. Now if for every

Harbhagwan Harbhajan Lal, Chandigarh vs. DCIT, Cl. 1(1), Chandigarh

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

ITA 796/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh16 Apr 2025AY 2018-19
For Appellant: Shri Jaspal Sharma, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 144rSection 145Section 270ASection 271BSection 44A

explanation submitted by the assessee. 8.1 The Assessing Officer shall grant the assessee a reasonable opportunity of being heard and shall pass a speaking order after due consideration of all submissions, material, and documents placed on record. However, having regard to the substantial turnover of Rs. 47.02 crores

Mahesh Yadav Alam, Secunderabad vs. ITO., Ward-15(1), Hyderabad

In the result, both the captioned appeals are disposed of in terms of the aforesaid observations

ITA 406/HYD/2025[2015-16]Status: DisposedITAT Hyderabad16 Apr 2025AY 2015-16

Bench: Us:

Section 144Section 147Section 148Section 149Section 234ASection 69

submitted that the CIT(A) has grossly erred in law and facts of the case in summarily dismissing the appeal based on a non-speaking order. The ld.AR to fortify his contention had taken us through the observations of the CIT(A). The ld. AR submitted that

Mahesh Yadav Alam, Secunderabad vs. ITO., Ward-15(1), Hyderabad

In the result, both the captioned appeals are disposed of in

ITA 405/HYD/2025[2013-14]Status: DisposedITAT Hyderabad16 Apr 2025AY 2013-14
Section 144Section 147Section 148Section 149Section 234ASection 69

submitted that the CIT(A) has grossly erred in law and facts of the case in summarily dismissing the appeal based on a non-speaking order. The ld.AR to fortify his contention had taken us through the observations of the CIT(A). The ld. AR submitted that ... failed to advert to the specific issues involved in the appeal and disposed of the same based on a speaking order, therefore, the order so passed by him cannot be sustained and is liable to be struck down on the said count itself. 12. Per contra, Shri Rajan Agrawala, Senior

Rudvin Enterprises, Hyderabad vs. Income Tax Officer, Ward-14(2), Hyderabad

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

ITA 119/HYD/2025[2017-18]Status: DisposedITAT Hyderabad16 Apr 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.119/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Rudvin Enterprises Vs. Income Tax Officer Hyderabad Ward 14(2) Pan:Aasfr0495C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate P Vinod राज" व "ारा/Revenue By:: Shri Srinath Sadanala, Dr सुनवाई की तारीख/Date Of Hearing: 16/04/2025 घोषणा की तारीख/Pronouncement: 16/04/2025 आदेश/Order

For Appellant: Advocate P VinodFor Respondent: : Shri Srinath Sadanala, DR
Section 144

prosecution. Thus, it is clear that the learned CIT (A) has not decided the issues raised by the assessee on merit by a speaking order. Further, out of 3 notices issued by the learned CIT (A), one was issued during covid pandemic period and other 2 notices were issued within