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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

New Hansni Egg Centre, Sonebhadra vs. Income Tax Officer, Range - 3(3), Sonebhdra

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

ITA 114/VNS/2023[2017-2018]Status: DisposedITAT Varanasi16 Dec 2025AY 2017-2018

Bench: Shri Anadee Nath Misshra

further some addition made by the assessing officer on estimation was also partly allowed. Thus the order of learned CIT Appeal is not a speaking order and thus being aggrieved with the order the assessee is filing appeal on following grounds for adjudication.” 4. At the time of hearing

Jai Hind Souharda Pattin Sahakari Niyamit, Belagavi vs. Income Tax Officer, Ward - 1(3), Belagavi

The appeal is allowed for statistical purposes

ITA 168/PAN/2025[2012-13]Status: DisposedITAT Panaji16 Dec 2025AY 2012-13

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Jai Hind Souharda Sahakari Sangh Niyamit, Bazar Road, Tal.: Hukkeri, Belgavi-591309 Pan:Aaajj0226F . . . . . . . Appellant

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal[‘Ld. DR’]
Section 143(1)Section 143(3)Section 250Section 250(6)Section 251(1)(a)Section 251(2)Section 253(1)Section 80P

impugned order and remand the same to the stage of its institution with a direction deal therewith de-novo on merits and pass speaking order in terms of section 250(6) of the Act. 7. In result, the appeal is allowed for statistical purposes. In terms of rule

Mayurbhai Hirabhai Sindhav (Maldhari), Rajkot vs. Income Tax Officer Ward 2(1)(2), Rajkot

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

ITA 571/RJT/2025[2012-13]Status: DisposedITAT Rajkot16 Dec 2025AY 2012-13

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 250

144/143(3) of the Act and the impugned order passed by the ld. CIT(A), is an ex parte order and non-speaking order, therefore, we do not wish to make any comments on the merits of the grounds raised by the assessee. We note that it is settled ... case, in the interest of justice, we restore the matter back to the file of assessing officer 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

Mayurbhai Hirabhai Sindhav ( Maldhari), Rajkot vs. Income Tax Officer Ward 2(1)(2), Rajkot

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

ITA 570/RJT/2025[2011-12]Status: DisposedITAT Rajkot16 Dec 2025AY 2011-12

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 250

144/143(3) of the Act and the impugned order passed by the ld. CIT(A), is an ex parte order and non-speaking order, therefore, we do not wish to make any comments on the merits of the grounds raised by the assessee. We note that it is settled ... case, in the interest of justice, we restore the matter back to the file of assessing officer 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

Prakashbhai Madhavjibhai Thummar, Rajkot vs. The ITO WD-3 (1) (2) Rajkot, Rajkot

In the result, the appeal of the assessee is allowed for statistical purposes Order pronounced in the open court on 16-12-2025

ITA 306/RJT/2025[2011-12]Status: HeardITAT Rajkot16 Dec 2025AY 2011-12

Bench: Dr. Arjun Lal Sainiand

For Appellant: Shri Sumit Shingala, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 144

carried out u/s 144 of the Act and the impugned order passed by the ld. CIT(A), is an ex parte order and non-speaking order, therefore, we do not wish to make any comments on the merits of the grounds raised by the assessee. I.T.A No. 306/Rjt/2025

Thakorbhai Maganbhai Patel, Vadodara vs. The ITO, Ward- 3(1)(1), Vadodara

ITA 532/AHD/2023[2008-09]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2008-09

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Sakar Sharma, ARFor Respondent: Shri Kamal Deep Singh, Sr. DR
Section 131Section 142(1)Section 143(3)Section 147Section 148Section 2(14)(iii)Section 271(1)(c)

assessee objected to the reopening on legal grounds, contending that no income had escaped assessment and that no separate speaking order was passed on objections as mandated by the decision of the Hon’ble Supreme Court in GKN Driveshafts. The assessee also challenged the reopening before the Hon’ble Gujarat ... issuance of notice under section 148, contending that there was no escapement of income and that objections were not disposed of by a separate speaking order. On merits, the assessee contended that the land sold was agricultural land and not a capital asset, that capital gains could not be taxed

Belathur Srinivasaiyengar Rangaiyengar, Mysore vs. Income Tax Officer, Ward-1(1), Mysore

In the result, appeal of the assessee is allowed

ITA 574/BANG/2025[2017-18]Status: DisposedITAT Bangalore16 Dec 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Sri Lokanath S., A.RFor Respondent: Sri Balusamy N., D.R
Section 143(2)Section 143(3)Section 250Section 269SSection 44A

approach adopted by the AO in making the addition. The ld. CIT(A)/NFAC also held that the AO has passed a reasoned and speaking order considering all the facts and circumstances of the case and no interference with the order of the AO is called for. Belathur Srinivasaiyengar Rangaiyengar

Orange Fish Entertainment Prvite Limited, Mumbai vs. DCIT 13(1)(1), Mumbai

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

ITA 5213/MUM/2025[2013-14]Status: DisposedITAT Mumbai16 Dec 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2013-14

For Appellant: Mr. Nitesh Joshi a/wFor Respondent: Mr. Virabhadra Mahajan, Sr. DR

dispose of appellate authority under section 250(6) of the Act is to dispose of the appeal on merits by passing a speaking order, setting out the the appeal on merits by passing a speaking order, setting out the the appeal on merits by passing a speaking order, setting ... adjudicate the appeal afresh the learned CIT(A) with a direction to adjudicate the appeal afresh on merits by passing a reasoned and speaking order in accordance on merits by passing a reasoned and speaking order in accordance on merits by passing a reasoned and speaking order in accordance with

Avon Cycles Limited, G.T Road, Dhandari Kalan, Ludhiana vs. Pr. Commissioner of Income Tax, 1, Rishi Nagar, Ludhiana

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

ITA 705/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh15 Dec 2025AY 2021-22

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं/. Ita No. 705/Chd/2025 िनधा"रणवष" / Assessment Year: 2021-22 Avon Cycles Ltd., Vs The Pcit-I, G.T.Road, Dhandari Kalan, Rishi Nagar, Ludhiana. Ludhiana. "थायीलेखासं/.Pan No: Aabca4140R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashish Aggarwal, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15/12/2025 Physical Hearing Order Per Laliet Kumar, Jm This Appeal Filed By The Assessee Is Directed Against The Order Of The Principal Commissioner Of Income Tax, Ludhiana-1 (Hereinafter Referred To As The "Pcit"), Dated 27.03.2025, Passed Under Section 263 Of The Income Tax Act, 1961 (The "Act") For The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Substantive Grounds Of Appeal: “1. That Ld. Pcit -1, Ludhiana, Erred In Law & On Facts In Assuming The Jurisdiction To Invoke The Provisions Of Section 263 Of The Act To Set Aside The Order Passed By The Assessing Officer (National Faceless Assessment Centre, Delhi) When The Order Was Neither Erroneous Nor Prejudicial To The Interest Of Revenue. The Order Passed By Ld. Pcit(1), Ludhiana, Being Illegal Unjustified & Against The Provisions Of Section 263 May Be Annulled. 2. That Ld. Pcit (1) Erred In Law & On Facts In Setting Aside The Order Of Assessing Officer (National Faceless Assessment Centre, Delhi) By Applying The Different Approach On The Same Set Of Facts On The Issues Already Considered By The Assessing Officer.

For Appellant: Shri Ashish Aggarwal, CAFor Respondent: Shri Manav Bansal, CIT, DR
Section 143(3)Section 194JSection 263Section 69C

144B of Income Tax Act, 1961. Needless to state, the Assessing Officer shall give the assessee reasonable opportunity of being heard and pass a speaking order after taking into consideration the explanation and supporting evidence submitted by the assessee. The assessment order dated 26.12.2022, passed u/s 143(3) r.w.s. 144B

Bebo Educational Charitable Trust, Chandigarh vs. Commissioner of Income Tax, Exemptions, Chandigarh

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

ITA 440/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh15 Dec 2025AY 2022-23

Bench: The Proceeding Limitation Date Of 31.01.2025 & As Such The Order Passed Is Illegal, Arbitrary & Unjustified. 2. That The Ld. Commissioner Of Income Tax(Exemptions) Has Erred In Law As Well As On Facts In Rejecting The Application Filed For Registration U/S 12Ab Alleging

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Smt. Tarundeep Kaur, CIT, DR(Virtual Mode)
Section 12ASection 12A(1)(ac)

limitation, deemed approval, and compliance with statutory requirements under Section 80G(5) of the Act. The Ld. CIT(E) shall pass a reasoned and speaking order after granting due and adequate opportunity of hearing to the assessee. 6.3 We clarify that we have not expressed any opinion on the merits

Bebo Educational Charitable Trust, Chandigarh vs. Commissioner of Income Tax, Exemptions, Chandigarh

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

ITA 439/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh15 Dec 2025AY 2022-23

Bench: The Proceeding Limitation Date Of 31.01.2025 & As Such The Order Passed Is Illegal, Arbitrary & Unjustified. 2. That The Ld. Commissioner Of Income Tax(Exemptions) Has Erred In Law As Well As On Facts In Rejecting The Application Filed For Registration U/S 12Ab Alleging

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Smt. Tarundeep Kaur, CIT, DR(Virtual Mode)
Section 12ASection 12A(1)(ac)

limitation, deemed approval, and compliance with statutory requirements under Section 80G(5) of the Act. The Ld. CIT(E) shall pass a reasoned and speaking order after granting due and adequate opportunity of hearing to the assessee. 6.3 We clarify that we have not expressed any opinion on the merits

Samir Fakirmahamad Meman, Mehsana vs. The ACIT/DCIT, Circle- Gandhinagar, Gandhinagar

The appeal of the assessee is treated as allowed for statistical purposes

ITA 1399/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad15 Dec 2025AY 2014-15

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No. 1399/Ahd/2025 िनधा"रण वष" /Assessment Year : 2014-15 Samir Fakirmahamad Meman The Acit/Dcit, बनाम/ Prop. Samir Fruits 5, Circle - Gandhinagar V/S. Vegetable Market, Gandhinagar - 382 011 Mehsana, (Gujarat) Gujarat – 384 002 "थायी लेखा सं./Pan: Aorpm 8847 C (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Kunal Sanghavi, Ar Revenue By : Shri Rigesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/ 09/2025 घोषणा की तारीख /Date Of Pronouncement: 15/12/2025 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Kunal Sanghavi, ARFor Respondent: Shri Rigesh Das, CIT-DR
Section 250Section 68

hereby condoned. The Ld. CIT(A) is directed to decide the case of the assessee on merits by way of a speaking order in accordance with law. The Ld. CIT(A), if he so requires, may call upon the remand report from the AO on any/all of the issues involved

Takshashila Dhoraji Infrastructure, Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

The appeal of the assessee is treated as allowed for statistical purposes

ITA 1999/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad15 Dec 2025AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No. 1999/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Takshashila Dhoraji The Deputy Commissioner Of बनाम/ Infrastructure, Income Tax, V/S. Takshashila House, Near Circle 2(1)(1), Krishna Baug Cross Road, Ahmedabad – 380 015 Maninagar, Ahmedabad – 380008 "थायी लेखा सं./Pan: Aagft 6032 P (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Mehul K Patel, Ar Revenue By : Shri Rajeev Garg, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 18 /09/2025 घोषणा की तारीख /Date Of Pronouncement: 15/12/2025 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Mehul K Patel, ARFor Respondent: Shri Rajeev Garg, Sr.DR
Section 147Section 250Section 69

DCIT Asst. Year : 2018-19 to the assessee to present its case and thereafter to pass the assessment order afresh by way of a speaking order and in accordance with law. 5. With the above observations, the appeal of the assessee is treated as allowed for statistical purposes. Order pronounced

Bharati Nimba Patil, Nashik vs. National Faceless Assessment Centre, Delhi

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

ITA 503/PUN/2025[2014-15]Status: DisposedITAT Pune15 Dec 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.503/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 Bharati Nimba Patil, Vs. Ito, Nfac, Delhi. S. No.235, P. No.53, 54, Shri Datta Krupa Kalanagar Mhasarul, Behind Aakash Petrol Pump, Nashik- 422004. Pan : Akapp7755P Appellant Respondent Assessee By : Shri Sanket M. Joshi (Virtual) Revenue By : Shri Bharat Andhale (Virtual) Date Of Hearing : 02.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.09.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1] The Learned Cit(A) Erred In Dismissing The Appeal In Limine & Thereby Confirming The Addition Of Rs.48,75,000 Made By The A.O. In The Ex-Parte Asst. Order U/S 144 R.Ws. 147 Passed During Covid Period, By Taxing The Entire Consideration Received On Sale Of Agricultural Land As Stcg Without Verifying The Contention Raised In Form 35 That The Impugned Land Was Rural Agricultural

For Appellant: Shri Sanket M. Joshi (Virtual)For Respondent: Shri Bharat Andhale (Virtual)
Section 143(3)Section 144Section 147Section 148Section 2(14)

Arjundas Luthra [(2017) 297 CTR 614] and hence, the said appeal may be restored to the file of the CIT(A) for passing a speaking order on merits afresh. 5] The appellant craves leave to add/alter/ amend any of the grounds of appeal.” 3. There is delay in filing

Income Tax Officer, Ward-9(1), Kolkata vs. Sanmukh Vincom Private Limited, Hyderabad

In the result, the appeal of the Revenue is dismissed

ITA 1238/KOL/2025[2014-15]Status: DisposedITAT Kolkata15 Dec 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Income Tax Officer, Ward 9(1), Sanmukh Vincom Private Kolkata Limited 5Th Floor, Room No.5/12/2B, 15-2-380/382, Landmark Centre, Aaykar Bhawan, P-7, Shop No.3, Siddiamber Bazar, Vs. Chowringhee Square, Hyderabad, Telangana-500012, Kolkata-700069, West Bengal Hyderabad (Appellant) (Respondent) Pan No. Aalcs9735Q Assessee By : Shri Siddharth Jhajharia, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 02.12.2025 Date Of Pronouncement: 15.12.2025

For Appellant: Shri Siddharth Jhajharia, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 148Section 148ASection 69A

taken a correct view Sanmukh Vincom Private Limited; A.Y. 2014-15 of the matter by passing a very reasoned and speaking order which does not require any interference at our end. Accordingly, we uphold the appellate order passed by ld CIT(A) by dismissing the appeal of the Revenue

Aadarsh Surana, Chennai vs. Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1840/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Dec 2025AY 2017-18
For Appellant: Shri. R.Venkata Raman, C.AFor Respondent: Shri. Shiva Srinivas, CIT
Section 142(1)Section 143(2)Section 143(3)Section 250Section 47Section 68

u/s.250 of the Act, dismissed the appeal of the assessee without affording a reasonable opportunity of being heard and rendered an ex-parte, non-speaking order without adjudicating the grounds on merits. Aggrieved by the said order, the assessee preferred an appeal before this Tribunal. This Tribunal, vide order dated ... Ld.CIT(A) and remitted the matter back to his file with a direction to consider the issues on merits and to pass a speaking order after providing due opportunity to the assessee. In compliance with the directions of this Tribunal, the Ld.CIT(A) restored the appeal to his file

Poonam Sodhi, Gurgaon vs. ITO, Gurgaon

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 7105/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Dec 2025AY 2017-18

Bench: Shri Vikas Awasthyआअसं.7105/धिल्ली/2025 (नि.व. 2017-18) Poonam Sodhi, 5217, Dlf Phase Iv, Dlf City, Gurgaon, Haryana 122002 ...... अपीलार्थी/Appellant Pan: Bfvps-5961-R बिाम Vs. Income Tax Officer, Hsiidc Building, Vanijya Nikunj, Udhyog Vihar, Phase-V, ..... प्रनिवादी/Respondent Gurgaon, Haryana 122001 अपीलार्थी द्वारा/Appellant By : Shri Saurabh Sharma, Advocate प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 15/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Additional/Joint Commissioner Of Income Tax (Appeals)-2, Vododara [In Short ‘The Cit(A)’] Dated 04.07.2024, For Assessment Year 2017-18. 2. Shri Saurabh Sharma, Appearing On Behalf Of The Assessee Submits That The Assessee Filed Her Return Of Income For The Assessment Year Under Consideration Declaring Total Income Of Rs. 8,03,000/- Comprising Of Income From House Property & Interest Income. The Case Was Selected For Limited Scrutiny Under Cass To Examine Large Cash Deposits During Demonetization Period Vis-À-Vis The Returned Income. Statutory Notices U/S. 143(2) & 142(1) Of The Income Tax

For Appellant: Shri Saurabh Sharma, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR
Section 143(2)Section 250Section 250(6)Section 69A

power to dismiss appeal for non-prosecution. The First Appellate Authority is statutorily required to adjudicate the appeal on merits by passing a speaking order dealing with each ground of appeal raised by the assessee. This obligation on CIT(A) to dispose of appeal on merits flow from the provisions

Avg Logistics Limited, New Delhi vs. Asst. Director of Income Tax, CPC, Bengaluru

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

ITA 242/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Dec 2025AY 2020-21

Bench: Shri C. N. Prasad & Shri M. Balaganeshavg Logistics Ltd, Vs. Asst. Director Of Income 25, Dda Market, Tax, Nirman Vihar, East Cpc, Bengaluru Delhi, Delhi (Appellant) (Respondent) Pan: Aaica1669A Assessee By : None Revenue By: Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing 24/09/2025 Date Of Pronouncement 15/12/2025

For Appellant: NoneFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(1)Section 43B

allowed in full or in part, and in sustaining the AO‟s additions/disallowances. 7. That the learned Addl./JCIT (A) failed to pass a speaking order, and as such, the appellant‟s rights to a fair and reasoned decision were prejudiced, as no adequate reasons were provided for dismissing ... novo adjudication in accordance with law qua the issues in dispute before us. The ld AO shall pass a speaking order after duly considering the aforesaid submission and fresh submissions, if any, in this regard. Accordingly, grounds raised by the assessee are allowed for statistical purposes. In the result

Compunnel Technology India (P) Ltd, Noida vs. ACIT Circle-4(2), New Delhi

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

ITA 550/DEL/2021[2016-17]Status: DisposedITAT Delhi15 Dec 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Amitabh Shukla[Assessment Year:2016-17] Compunnel Technology India Assistant Commissioner Of Income Private Limited, Tax, Circle-4(2), C-4, Sector-58, Noida, Vs New Delhi Uttar Pradesh-201301 Pan Aaaci5095A Appellant Respondent Assessee By Shri Dinesh Gupta, Ar Revenue By Shri Dharm Veer Singh, Cit(Dr) Date Of Hearing 15.12.2025 Date Of Pronouncement 15.12.2025

Section 144Section 92CSection 92D

Assessee and the AE put together 8.2 On facts and in law the Ld. DRP erred in law in not passing a speaking order with respect to Objection No. 11 filed before the Panel. 9.1 Without prejudice to the above grounds, since the assessment was picked up towards ... against the CUP method adopted by the assessee. The assessee has also contested that the DRP has summarily rejected its contest without passing a speaking order. Further, the appellant assessee has also submitted that as the assessment proceedings were initiated towards the fag end, it was deprived of adequate opportunity

Anket Pagariya, Raipur vs. ACIT, Central Circle-1, Raipur

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

ITA 745/RPR/2025[2018-19]Status: DisposedITAT Raipur12 Dec 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.745/Rpr/2025 "नधा"रण वष" /Assessment Year : 2018-19 Anket Pagariya 118-119, C/O. Pagaria Jewellers, Halwai Lane, Sadar Bazar, Raipur (C.G.)-492 001 Pan: Aovpp8778F

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250Section 250(4)

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