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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

Sachin Maganlal Kotak, Bhuj-Kutch vs. ITO Ward-4, Gandhidham-Bhuj-2

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

ITA 233/RJT/2024[2016-2017]Status: DisposedITAT Rajkot27 Feb 2025AY 2016-2017

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 233 /Rjt/ 2024 ("नधा"रण वष"/Assessment Year: (2016-17) Sachin Maganlal Kotak Ito, Ward-4, Gandhidham (Bhuj-2) New Wholesale Market Bhuj, Kutch – Vs. Income-Tax Office, Plot No. 32, Sector 370001 No.3, Near Iffco Colony, Gandhidham - 370201 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Amipk0858L (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Fenil H. Maheta, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. (DR)
Section 147Section 250(6)

interest of justice, we restore the matter back to the file of Ld. CIT(A) for de novo adjudication and pass a speaking order after affording sufficient opportunity of being heard to the assessee, who in turn, is also directed to contest his stand forthwith. Therefore, we deem

Nishi Kant, Patna vs. ITO, Ward-5(3), Patna

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

ITA 569/PAT/2024[2015-16]Status: DisposedITAT Patna27 Feb 2025AY 2015-16

Bench: Shri George Mathan & Shri Sanjay Awasthiassessment Year: 2015-16

For Appellant: N o n eFor Respondent: Shri Ashwani Kr. Singal, JCIT
Section 250Section 250(6)

matter back to the file of Ld. CIT(A) for a disposal on merits of the grounds taken by the assessee, by passing a speaking order. Needless to say that assessee will be given a reasonable opportunity of being heard to make any further submission he wants to make

Anmol Kumar, Bhagalpur vs. ITO Ward 2(1), Begusarai

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

ITA 343/PAT/2023[2017-18]Status: DisposedITAT Patna27 Feb 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 343/Pat/2023 Assessment Year: 2017-2018 Anmol Kumar,……………………….……….....Appellant Tulsipur, Via Khirik Bazar, Naugachhiya, Bhagalpur-853202, Bihar [Pan:Aqupk8693D] -Vs.- Income Tax Officer,……….………………….Respondent Ward-2(1), Begusarai, Begusarai-851101, Bihar Appearances By: Shri Sudeep Sinha, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 30, 2024 Date Of Pronouncing The Order: February 27, 2025 O R D E R

Section 148Section 69A

file of ld. Assessing Officer with a direction to provide one more opportunity of being heard to the assessee and to pass a detailed speaking order. At the same time, we direct the assessee to place the paper books, which were filed before us, to be placed before

Winsome Textile Industries Limited, Chandigarh vs. Asstt. Commissioner of Income Tax, Circle-4(1), Chandigarh

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 528/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Ved Parkash Kalia Sr. DR
Section 115JSection 143(1)Section 143(3)Section 147Section 148

notice is entitled to file objections to issuance of notice and the Assessing Officer is bound to dispose of the same by passing a speaking order. In the instant case, as the reasons have been disclosed in these proceedings, the Assessing Officer has to dispose of the objections, if filed ... passing a speaking order, before proceeding with the assessment in respect of the abovesaid five assessment years." 22. In Lovely Exports (P.) Ltd.'s case (supra), the Apex Court held thus :— "2. Can the amount of share money be regarded as undisclosed income under section 68 of Income

Dharmishthaben Shaileshbhai Patel, Ahmedabad vs. The ITO, Ward-3(3)(6), Ahmedabad

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

ITA 2008/AHD/2024[2009-10]Status: DisposedITAT Ahmedabad27 Feb 2025AY 2009-10

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Nimesh Vayawala, A.RFor Respondent: Shri J. L. Bhatia, Sr. DR
Section 143(3)

that Ld. CIT(Appeals) while passing the appellate order has dismissed the appeal of the assessee on ex-parte basis by passing a non-speaking order, without taking into consideration the detailed statement of facts and the grounds of appeal raised by the assessee. The counsel for the assessee submitted ... facts of the case and the contents of the order passed by Ld. CIT(Appeals), we observe that he has passed a non-speaking order, without either discussing the detailed submissions relating to the facts of the assessee’s case (as given by the assessee the statement of facts

Mr Harilal Santhosh, Mumbai vs. Income Tax Officer Ward 33(1)(5), Mumbai

In the result, the grounds of appeal raised by the assessee are allowed for

ITA 774/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Feb 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Omkareshwar Chidaraआयकर अपील सं./Ita No. 774/Mum/2024 (Ay 2017-18) (Physical Court Hearing) Mr. Harilal Santhosh, 47/48, Kakad Kunj, Dwarkesh Park, Kandivali (West), Mumbai-400067. [Pan : Ajjps 0926 P] अपीलार्थी/Appellant Vs Income Tax Officer Ward- 33(1)(5), Room No. 915, 9Th Floor, Kautilya Bhawan, C-41 To C-43, G Block, Bandra Kurla Complex, Bandra East, Mumbai-400051. प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee By Sh. Bharat Gandhi, Ar राजस्व की ओर से / Revenue By Sh. Anil Gupta Sr Dr सुनवाई की तारीख/Date Of Hearing 27.02.2025 उद्घोषणा की तारीख/Date Of Pronouncement 27.02.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh; 1. This Appeal By Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [For Short To As “Nfac/Ld.Cit(A)"] Dated 03.01.2024 For

Section 115BSection 144Section 156Section 249(4)(b)Section 254(1)Section 69A

assessee for the want of deposit of self-assessment tax. The appeal of the assessee was dismissed and un-admitted in a non-speaking order. The Ld. AR of the assessee submits that matter may be restored back to the file of the Ld. CIT(A) for adjudicating the appeal

Woodfun, Mumbai vs. ACIT Circle 17(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 6977/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Feb 2025AY 2013-14

Bench: Shri Saktijit Dey, Vp & Shri Narendra Kumar Billaiya, Am Woodfun Acit, Circle-17(1) Gurbir Singh Makni Partner Of Mumbai M/S. Woodfun Partnership Firm E-13, Surhdayak Society, Vs. J.B. Nagar, Andheri East, Mumbai-400 059

For Appellant: Shri Faisal VoraFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143(3)

first appellate authority relied upon couple of judicial precedents and dismissed the appeal in limine without deciding the appeal on merits through a speaking order. In our view, as per the provisions of the Act, the first appellate authority has to decide the appeal filed before him/her on merits. Even ... first appellate authority is directed to provide reasonable opportunity of being heard to the assessee and decide the appeal on merits through a speaking order. Hence, grounds are allowed for statistical purposes. 4. In the result, the appeal is allowed for statistical purposes. Order pronounced in the open court

Novanet India Private Limited, Mumbai vs. ITO Ward Ward 15(2)(1), Mumbai

The appeal of the assessee is allowed

ITA 4505/MUM/2024[2018-19]Status: DisposedITAT Mumbai27 Feb 2025AY 2018-19

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Vishal Shah a/w Jainam
Section 112Section 147Section 148Section 148ASection 201Section 250Section 9(1)(vii)

facts and under the circumstances of the case and in law, the Learned CIT(A) erred in passing a non-speaking order u/s 250 which is bad in law. b) On the facts and under the circumstances of the case and in law, the learned CIT(A) erred in passing ... order by treating purchase of minutes from foreign party as a technical service by merely relying on Union Carrier Services Agreement without passing a speaking order as to why the same would fall within the definition of technical service u/s 9(1)(vii) and without providing any justification

ACIT, New Delhi vs. M/S. Saurer Embroidery Systems India Pvt. Ltd., New Delhi

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

ITA 3508/DEL/2012[2002-03]Status: DisposedITAT Delhi27 Feb 2025AY 2002-03

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Abhimanyu Jhamba, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 115BSection 142Section 145(3)Section 69A

with the Appellant. 4. That on the facts and circumstances of the case and in law, the Ld. CIT (A) has not passed a speaking order or given his own findings on the ground of erroneous rejection of books

Classic Growers Ltd., Kolkata vs. A.C.I.T., Circle - 7(1), Kolkata

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

ITA 2098/KOL/2024[2012-2013]Status: DisposedITAT Kolkata26 Feb 2025AY 2012-2013

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2098/Kol/2024 Assessment Year: 2012-2013 Classic Growers Limited,…….….…..…………Appellant Room No. 68A, 2Nd Floor, Karnani Estate, 209, A.J.C. Bose Road, Kolkata-700017 [Pan:Aabcc3758M] -Vs.- Assistant Commissioner Of Income Tax,...Respondent Circle-7(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, 5Th Floor, Kolkata-700069 Appearances By: Shri Vinit Jalan, C.A., Appeared On Behalf Of The Assessee Shri L.N Dash, Addl. Cit, D.R., Appeared On Behalf Of The Revenue

Section 143(3)

Officer in order to meet the principle of natural justice and to examine the additional evidence filed by the assessee and pass a detailed speaking order. I also direct the ld. Counsel for the assessee to file all the relevant documents before the ld. Assessing Officer to substantiate the case

Sunita Garg, Kolkata vs. ITO, Ward 43(1), Kolkata

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

ITA 1382/KOL/2023[2011-12]Status: DisposedITAT Kolkata26 Feb 2025AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 1382/Kol/2023 Assessment Year: 2011-2012 Sunita Garg,……………………….…..…………Appellant 36A, Sahitya Parishad Street, Kolkata-700006 [Pan:Adspg1683J] -Vs.- Income Tax Officer,…………………………....Respondent Ward-43(1), Kolkata, 3, Government Place (West), Kolkata-700001 Appearances By: Shri A.K. Tibrewal, Fca & Shri Saurabh Gupta, Fca, Appeared On Behalf Of The Assessee Shri P.N. Barnwal, Cit, D.R. & Smt. Ranu Biswas, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 28, 2025 Date Of Pronouncing The Order: February 26, 2025 O R D E R

Section 143(2)Section 144Section 148Section 68

Assessing Officer in order to meet the principle of natural justice and to examine the evidences filed by the assessee and pass a detailed speaking order. We also direct the ld. Counsel for the assessee to file all the relevant documents before the ld. Assessing Officer to substantiate the case

Income Tax Officer, Ward-11(1), Kolkata, Aayakar Bhawan, Chowringhee Square vs. Positive Devcon Pvt. Ltd., Sonarpur

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

ITA 1123/KOL/2023[2011-12]Status: DisposedITAT Kolkata26 Feb 2025AY 2011-12

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

Section 114Section 143(3)Section 250Section 263Section 271(1)(c)

after granting an opportunity of being heard to the Ld. AO as well as the assessee and thereby decide the appeal by passing a speaking order. 7. In the result, the appeal filed by the revenue is allowed for statistical purposes. Order pronounced in the open Court on 26th February

Aruna Alloy Steels Privates Limited, Madurai vs. ACIT, Corp. Circle-1, Madurai, Maduraiq

In the result, appeal filed by the assessee is allowed

ITA 2803/CHNY/2024[2016-17]Status: DisposedITAT Chennai26 Feb 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Respondent: Mr.Ashwin D. Gowda
Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 156Section 80I

account of two folds. (i) On Interpretation of statues: M/s.Aruna Alloy Steels Pvt. Ltd. :: 7 :: B) The Honourable Supreme Court in its detailed speaking order dated 11 July, 2022, while deciding a claim of deduction u/s.10B of the Act, in the case of Wipro Ltd, after detailed consideration of various

Vishvanath, Kaushambi vs. Income Tax Officer- 2(5), Kaushambi

In the result, the appeal is allowed for statistical purposes

ITA 159/ALLD/2024[2017-18]Status: DisposedITAT Allahabad25 Feb 2025AY 2017-18

Bench: Shri Subhash Malguria & Shri Nikhil Choudhary

Section 142(1)Section 147

case should be restored back to the file of the learned CIT(A) because the learned CIT(A) is duty bound to pass speaking order on merits. The learned Sr. Departmental Representative for Revenue expressed no objection to this. 4. We have heard the rival parties and have gone through ... 25/06/2024 of the learned CIT(A) and we direct the learned CIT(A) to decide the appeal through de novo order which should be speaking order on merits and in accordance with law after providing reasonable opportunity to the assessee and ensuring due compliance of requirements

Vinay Kumar Gupta, Hardoi vs. ITO-3(2), Hardoi

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

ITA 16/LKW/2025[2015-16]Status: DisposedITAT Lucknow25 Feb 2025AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshravinay Kumar Gupta Ito-3(2) V. C/O Sanjay Saxena, 12, Pratap Income Tax Office, Enclave, Bisrat Gt Road, Nagheta Road, Uttar Shahjahanpur-242001. Pradesh-241001. Pan: Amwpv7973K (Appellant) (Respondent) Appellant By: Shri Sanjay Saxena, C.A. Respondent By: Shri Sanjeev Krishna Sharma, Addl. Cit(Dr) O R D E R

For Appellant: Shri Sanjay Saxena, C.AFor Respondent: Shri Sanjeev Krishna Sharma, Addl
Section 144BSection 147Section 148Section 250Section 250(6)Section 69Section 69A

First Appellate Order were passed exparte qua the assessee. He further submitted that the impugned order of the Ld. CIT(A) is not a speaking order on merits of the additions made. He further submitted that the assessee’s appeal was dismissed in limine for want of prosecution without ... office of the Ld. CIT(A). However, the Ld. CIT(A) has statutory duty, prescribed u/s 250(6) of the Act to pass a speaking order on the merits of the case, whether or not there was any representation from the assessee’s side. The order

Mohd Husain, Murar Mau Sareni, Lalganj vs. ITO -01 Raebareli-New, Raebareli

In the result, the appeal is allowed for statistical purposes

ITA 628/LKW/2024[2017-20218]Status: DisposedITAT Lucknow25 Feb 2025

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 270A

notice was given by the learned CIT(A) through e- mail. He also submitted that the order of learned CIT(A) is not a speaking order. He also submitted that the Assessing Officer had passed the aforesaid order dated 21/09/2022 u/s 270A of the Act without providing reasonable opportunity

Anubhav Aggarwal, Ludhiana vs. ACIT, CC-1, Ludhiana

In the result, appeal of the assessee is dismissed

ITA 1288/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh25 Feb 2025AY 2014-15

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1288/Chd/2019 "नधा"रण वष" / Assessment Year : 2014-15 Anubhav Aggarwal, The Acit, बनाम #526-B, Aggar Nagar, Central Circle-1, Ludhiana 141001 Ludhiana Vs. "थायी लेखा सं./Pan No: Aaypa9742K अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: NoneFor Respondent: Shri Rohit Sharma, CIT DR
Section 68

passed by the Assessing Officer and the appellate order passed by the ld. CIT(A). We find that the Assessing Officer has passed a speaking order based on various incriminating documents 1288 -Chd-2019 Anubhav Aggarwal, Ludhiana 10 found and seized from various business and residential premise of the group ... Officer, the Assessee filed an appeal before the ld. CIT(A) on different grounds. The ld. CIT(A), in our view, has passed a speaking order on merit on each and every issue / ground raised by the Assessee in the appeal. The Assessee dissatisfied with the order

Anubhav Aggarwal, Ludhiana vs. ACIT, CC-1, Ludhiana

In the result, all the four appeals are dismissed

ITA 1287/CHANDI/2019[2013-14]Status: DisposedITAT Chandigarh25 Feb 2025AY 2013-14

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1287/Chd/2019 "नधा"रण वष" / Assessment Year : 2013-14 Anubhav Aggarwal, The Acit, #526-B, Aggar Nagar, बनाम Central Circle-1, Ludhiana Ludhiana Vs. 141001 "थायी लेखा सं./Pan No: Aaypa9742K अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: NoneFor Respondent: Shri Rohit Sharma, CIT DR
Section 127Section 132Section 139(1)Section 143(2)Section 153Section 68

passed by the Assessing Officer and the appellate order passed by the ld. CIT(A). We find that the Assessing Officer has passed a speaking order based on various incriminating documents found and seized from various business and residential premise of the group. Against the order of the Assessing Officer ... Anubhav Aggarwal, Ludhiana 8 different grounds. The ld. CIT(A), in our view, has passed a speaking order on merit on each and every issue / ground raised by the Assessee in the appeal. The Assessee dissatisfied with the order of the ld. CIT(A) has filed this appeal before

Anubhav Aggarwal, Ludhiana vs. ACIT, CC-1, Ludhiana

In the result, appeal of the assessee is dismissed

ITA 1286/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh25 Feb 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1286/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Anubhav Aggarwal, The Acit, #526-B, Aggar Nagar, बनाम Central Circle-1, Ludhiana Ludhiana Vs. 141001 "थायी लेखा सं./Pan No: Aaypa9742K अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: NoneFor Respondent: Shri Rohit Sharma, CIT DR
Section 127Section 132Section 139(1)Section 143(2)Section 153Section 68

passed by the Assessing Officer and the appellate order passed by the ld. CIT(A). We find that the Assessing Officer has passed a speaking order based on various incriminating documents found and seized from various business and residential premise of the group. Against the order of the Assessing Officer ... Anubhav Aggarwal, Ludhiana 9 different grounds. The ld. CIT(A), in our view, has passed a speaking order on merit on each and every issue / ground raised by the Assessee in the appeal. The Assessee dissatisfied with the order of the ld. CIT(A) has filed this appeal before

Anubhav Aggarwal, Ludhiana vs. ACIT, CC-1, Ludhiana

In the result, all the four appeals are dismissed

ITA 1285/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh25 Feb 2025AY 2011-12

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1285/Chd/2019 "नधा"रण वष" / Assessment Year : 2011-12 Anubhav Aggarwal, The Acit, #526-B, Aggar Nagar, बनाम Central Circle-1, Ludhiana Ludhiana Vs. 141001 "थायी लेखा सं./Pan No: Aaypa9742K अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: NoneFor Respondent: Shri Rohit Sharma, CIT DR
Section 127Section 132Section 139(1)Section 143(2)Section 153Section 68

passed by the Assessing Officer and the appellate order passed by the ld. CIT(A). We find that the Assessing Officer has passed a speaking order based on various incriminating documents 1285 -Chd-2019 Anubhav Aggarwal, Ludhiana 8 found and seized from various business and residential premise of the group ... Officer, the Assessee filed an appeal before the ld. CIT(A) on different grounds. The ld. CIT(A), in our view, has passed a speaking order on merit on each and every issue / ground raised by the Assessee in the appeal. The Assessee dissatisfied with the order