“non-speaking order”

Natural JusticeReasoned OrderReasoned Order793 judgments

The decision most relied on for non-speaking order is Kunhayammed v. State of Kerala (245 ITR 360), cited in 361 judgments on BharatTax.

Leading authorities on non-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.

Employees’ Welfare Assn. v. Union of India

4 SCC 187 · 1989 · Reported

citing judgments

Dismissal of a Special Leave Petition (SLP) in limine does not amount to a declaration of law under Article 141 of the Constitution, nor does it confirm the view of the lower court.

Sundaram Multi Pap Ltd. v. ACIT

164 Taxmann.com 414 · 2024 · High Court

citing judgments

An order passed under Section 148A(d) and subsequent proceedings are void if the Assessing Officer provides insufficient opportunity for the assessee to file a reply before issuing the notice under Section 148A(b).

Ms. Swati Pawa v. DCIT

103 Taxmann.com 300 · 2019 · High Court

citing judgments

The Commissioner (Appeals) may pass an order on the basis of material available on hand if the assessee fails to comply with notices despite sufficient opportunity. However, the Tribunal may restore appeals to the AO if similar cases on similar facts were restored.

Royal Bitumen (P.) Ltd. v. ACIT

164 Taxmann.com 606 · 2024 · High Court

citing judgments

Orders passed under section 148A(d) and subsequent reassessment proceedings are vitiated if the Assessing Officer fails to provide a proper opportunity of hearing to the assessee before issuing the notice.

Everest Kanto Cylinder Ltd. v. DCIT/ACIT

164 Taxmann.com 608 · 2024 · High Court

citing judgments

Orders under section 148A(d) are subject to appeal and the Supreme Court has upheld High Court decisions that considered them appealable. The dismissal of SLPs by the Supreme Court in related cases indicates a settled position on this matter.

16. Further, in Khoday Distilleries Ltd. & Others v. Sri Mahadeshwara Sahakara Sakkare Karkhane Limited, Kollegal

4 SCC 376 · 2019 · Reported

citing judgments

An order refusing special leave to appeal, whether speaking or non-speaking, does not attract the doctrine of merger and does not substitute the order under challenge.

State of Manipur v. Thingujam Brojen Meetai

9 SCC 29 · 1996 · Reported

citing judgments

A Supreme Court judgment dismissed by a non-speaking order does not constitute a declared law and is not binding under Article 141 of the Constitution of India.

Judgments citing non-speaking order

Norwest Venture Partners X - Mauritius, Mauritius vs. DCIT Circle Intl. Taxation 2(2)(2), New Delhi

ITA 2311/DEL/2023[2020-21]Status: DisposedITAT Delhi19 Mar 2024AY 2020-21

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia[Assessment Year: 2020-21]

Section 143(3)Section 144C(13)Section 71(4)

directions of learned DRP in letter and sprit and has simply repeated the additions made in the draft assessment order through a non-speaking order. 16. Strongly relying upon the observations of the Assessing Officer and learned DRP, learned Departmental Representative submitted that the Assessing Officer has brought enough facts

Dr. C Usha, Palakkad vs. ITO Ward-3, Palakkad

In the result, the assessee’s appeal is partly allowed and partly allowed for statistical purposes

ITA 657/COCH/2022[2013-2014]Status: DisposedITAT Cochin15 Mar 2024AY 2013-2014

Bench: Shri Sanjay Arora & Dr. Seethalakshmidr. C. Usha Income Tax Officer Modern Hospital Ward -3, Palakkad Guruvayur Road, Koottanad Vs. Palakkad 679533 [Pan:Aafpu8363H] (Appellant) (Respondent)

For Appellant: Shri K.V. Venkitaraman, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R

Section 143(3)

before us to be, filed subsequently, outstanding before the Tribunal. The assessment for AY 2014-15, though a regular assessment, is per a non-speaking order, without any finding and, therefore, of no assistance. The proceedings under the Act, a public law, it may be appreciated are not adversarial proceedings ... year. Assessment of income for that year at Rs.36 lakhs, as against returned Rs.40 lakhs, as for the current year, per a non-speaking order, would be of no consequence. The burden to prove that a receipt is in the nature of income is on the Revenue. However, once that

The Pr CIT Circle 5 (1), Bhopal vs. M/S M.P.Warehousing & Logistic Corporation, Bhopal

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

ITA 167/IND/2023[2013-14]Status: DisposedITAT Indore22 Feb 2024AY 2013-14

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniacit, Circle 5(1) M/S Mp Warehousing & Bhopal Logistics Corporation Office Complex, Block-1 Vs. Gautam Nagar Bhopal (Appellant / Revenue) (Respondent/ Assessee) Pan: Aadcm7742B Revenue By Shri Ashish Porwal, Sr-Dr Assessee By Shri Shri S.S. Deshpande Ar Date Of Hearing 12.12.2023 Date Of Pronouncement 22.02.2024

Section 35A

facts and circumstances might differ for year to year and CIT(A) hasn't stated facts and therefore has passed a non-speaking order without deciding or bringing the facts on record to support the contention of allowing assessee's claim. 9. On facts & in the circumstances of the case

M/S. Brightstar Vincom Pvt.Ltd., 700007 vs. I.T.A, Ward-3(3), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 176/KOL/2023[2012-13]Status: DisposedITAT Kolkata21 Feb 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.176/Kol/2023 Assessment Year: 2012-13 M/S Brightstar Vincom Pvt. Ltd…..…......................…...……………....Appellant 18/1, 4Th Floor, Room No.48, M.D. Road, Burrabazar, Kolkata-700007. [Pan: Aadcb2082R] Vs. Ito, Ward-3(3), Kolkata........…..........................................…..…..... Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 14, 2023 Date Of Pronouncing The Order : February 21, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 30.01.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

Section 142(1)Section 234Section 250Section 68

capital/share premium of Rs.3,58,00,000/- and he treated the said amount as unexplained income of the assessee by way of a non-speaking order and in a mechanical manner. The assessee had duly furnished all the details relating to the identity and creditworthiness of the creditors and genuineness

Q-872 Thiruthangal Primary Agricultural Co- Operative Credit Society Limited, Virudhunagar vs. ITO, Ward 3, Virudhunagar

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

ITA 1433/CHNY/2023[2021-22]Status: DisposedITAT Chennai19 Feb 2024AY 2021-22

Bench: Shri Mahavir Singh & Shri Manjunatha.Gआयकर अपीलसं./Ita No.: 1433/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 M/S. Q-872 Thiruthangal The Income Tax Officer, Primary Agricultural Co- Vs. Ward 3, Operative Credit Society Ltd., Virudhunagar. Thiruthangal, Virudhunagar – 626 130. Pan: Aaaaq 0201C (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Girish Kumar, Advocate ""यथ" क" ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 19.02.2024 घोषणा क" तारीख/Date Of Pronouncement : 19.02.2024

For Appellant: Shri S. Girish Kumar, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT

Section 143(1)(a)Section 144Section 250(6)Section 69ASection 69C

simpliciter confirmed the action of the AO and there is no adjudication on the facts and it is totally a non-speaking order. When a query was put to ld.counsel that from the face of the assessment order, it can be gathered that the AO has given various opportunities which

Babubhai Ramanbhai Patel, Ahmedabad vs. National Faceless Assessment Centre, Delhi Present Jurisdiction the ITO, Ward-1(2)(1), Ahmedabad

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

ITA 905/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad15 Feb 2024AY 2015-16

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Hemanshu Shah, A.RFor Respondent: Shri Sanjay Jain, Sr. D.R

Section 144Section 148

erred in facts and in law in summarily dismissing the assessee’s appeals for the assessment years under consideration, by passing a non-speaking order, without mentioning the various grounds of appeal raised by the assessee in his appellate order and without discussing the merits of the case. Therefore

Babubhai Ramanbhai Patel, Ahmedabad vs. The Dy.CIT, Circle-1(1)(1) Present Jurisdiction the ITO, Ward-1(2)(1), Ahmedabad

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

ITA 904/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad15 Feb 2024AY 2012-13

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri Hemanshu Shah, A.RFor Respondent: Shri Sanjay Jain, Sr. D.R

Section 144Section 148

Mr Sunil Shankar Bandal, Pune vs. Income Tax Officer, Ward.2(5), Pune

Appeal of the assessee is allowed for statistical purpose

ITA 1105/PUN/2023[2012-13]Status: DisposedITAT Pune14 Feb 2024AY 2012-13

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1105/Pun/2023 िनधा"रण वष" / Assessment Year : 2012-13 Mr.Sunil Shankar Bandal, The Income Tax Officer, At Post Bavdhan Bk, Taluka V Ward-2(5), Pune. Mulshi, Pune – 411021. S Pan: Ajkpb8627M Appellant/ Assessee Respondent /Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Shri Sourabh Nayak – Addl.Cit-Dr Date Of Hearing 14/02/2024 Date Of Pronouncement 14/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 22.08.2023. The Assessee Has Raised The Following Grounds Of Appeal : “1. On Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Act It Be Held That The Assessment Proceedings Initiated U/S 147 Of The Act Are Time Barred Since The Notice Issued U/S 148 Of The Act Is Served After 6 Years. Accordingly, The Assessment Proceedings So Initiated Be Kindly Quashed & Appellant Be Granted Just & Proper Relief In This Respect. Mr. Sunil Shankar Bandal [A]

Section 129Section 147Section 148Section 250

held that the Assessment Order passed, 6t so upheld, by making addition of Rs.1,13,30,760/- is a non-speaking order since Ld. AO has not at all mentioned under which provisions of 2 Mr. Sunil Shankar Bandal [A] the Act has the income been charged to tax. Accordingly

Leapfrog, Gulmohar Park vs. ITO, Ward 29(1), New Delhi

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

ITA 1774/DEL/2023[2012-13]Status: DisposedITAT Delhi14 Feb 2024AY 2012-13

Bench: Shri Shamim Yahyaleapfrog, Vs. Ito, Ward 29 (1), A-14, Third Floor, New Delhi. Gulmohar Park, New Delhi – 110 049. (Pan : Aaatl3565D) (Appellant) (Respondent) Assessee By : Shri Nitin Kanwar, Advocate Shri Rajeev Kumar, Advocate Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 11.01.2024 Date Of Order : 14.02.2024

For Appellant: Shri Nitin Kanwar, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 139Section 144Section 147Section 148Section 194CSection 271(1)(c)Section 3

have heard both the parties and perused the records. 6. I find that ld. CIT (A) passed a very cryptic and non-speaking order. The assessee also asked for virtual hearing but the same did not materialise. Hence, in my considered opinion, the interest of justice will be served

Lovely Promoters Private Limited, Kolkata vs. ACIT, Central Circle, Ajmer

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

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a

Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice ... raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice

Med-Link Devices (P) Limited, Mumbai vs. Commissioner of Income Tax 51, Mumbai

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

ITA 3321/MUM/2023[2013-14]Status: DisposedITAT Mumbai01 Feb 2024AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Upender KothiyalFor Respondent: Smt. Mahita Nair

Section 153Section 250Section 37(1)

medical practitioner and therefore prohibited in law. 5. BECAUSE the orders passed by the Ld. Assessing Officer as well as CIT(A) are non-speaking orders inasmuch as they do-not assign any reason and are conspicuously silent as to what are the exact nature of expenditures, which rather than

Aaditya Diamgold Pvt.Ltd., Ahmedabad vs. Income Tax Officer, Ward-1(1)(1), Ahmedabad

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

ITA 627/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad19 Jan 2024AY 2017-18

Bench: Shri Ramit Kochar & Ms. Suchitra Raghunath Kambleassessment Year : 2017-18 Aaditya Diamgold Pvt.Ltd. The Income Tax Officer 21, 1St Floor Iscon Arcade V. Ward-1(I)(I) Nr.Lal Bungalows Ahmedabad Cg Road Navrangpura Ahmedabad Gujarat – 380 009 Pan: Aalca 4525 A अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" य "" यथ" "" य "" य थ" थ"/ (Respondent) थ" Assessee By : Shri Parimal Sinh B. Parmar, Ar Revenue By : Shri Shri Atul Pandey, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 17/01/2024 घोषणा क" तारीख /Date Of Pronouncement: 17/01/2024 आदेश/O R D E R आदेश आदेश आदेश Per Ramit Kocharthis Appeal Filed By The Assessee Is Directed Against The Appellate Order Dated 14/07/2023 Passed By Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [“Cit(A)” In Short] Under Section 250 Of Sub-Section (6) Of The Income Tax Act, 1961(Hereinafter Called “The Act”) For Assessment Year 2017-18 (Din & Order No. Itba/Nfac/S/250/2023-24/ 1054374868(1)), The Appellate Proceedings Have Arisen Before Ld. Cit(A) From Assessment Order Dated 30.12.2019 Passed By Ld. Assessing Officer (Hereinafter Called “The Ao”) U/S 143(3) Of Aaditya Diamgold Pvt.Ltd. V. Ito Ay 2017-18

For Appellant: Shri Parimal Sinh B. Parmar, ARFor Respondent: Shri Shri Atul Pandey, Sr.DR

Section 143(3)Section 234BSection 250Section 250(6)Section 271ASection 68

Benches, Ahmedabad (hereinafter called “the Tribunal”): “1. The Ld. CIT(A) has erred in law and on facts in passing an unreasoned and non-speaking order without dealing with any of the contentions raised. Thus, Ld. CIT(A)'s order is bad in law as it suffers from the vice

M/S Arham Packaging Goods Pvt.Ltd., Kolkata vs. I.T.O., Ward-10(2), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 130/KOL/2019[2012-13]Status: DisposedITAT Kolkata08 Jan 2024AY 2012-13

Bench: Shri Sanjay Garg (Judicial Member), Shri Girish Agrawal (Accountant Member)

Section 131Section 250Section 68

capital/share premium of Rs.9,67,59,171/- and he treated the said amount as unexplained income of the assessee by way of a non-speaking order and in a mechanical manner. The assessee had duly furnished all the details relating to the identity and creditworthiness of the creditors and genuineness

Income Tax Officer, Ward-1, Chittoor vs. G Vijayasimha Reddy, Bengaluru

In the result, the appeal of Revenue in ITA

ITA 376/HYD/2023[2015-16]Status: HeardITAT Hyderabad05 Jan 2024AY 2015-16

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri Y V Bhanu NarayanFor Respondent: Ms. Sheetal Sarin, Sr. AR

Section 148Section 2(13)Section 54F

after concluding that the income received by the assessee was long term capital gain. We find the ld.CIT(A) in a cryptic and non-speaking order has held that the assessee is entitled to the benefit of section 54F. In our view, since the issue has not been decided

Iris Clothings Ltd, Howrah vs. DCIT, Circle-11(1), Kolkata

In the result the appeal of the assessee is allowed

ITA 1015/KOL/2023[2013-14]Status: HeardITAT Kolkata02 Jan 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Rajesh Kumar

Section 133(6)Section 143(3)Section 68

assessee by upholding the observations of the ld. Assessing Officer as made in the assessment order by passing a cryptic and non-speaking order. 6. The ld. A.R. vehemently submitted before us that during the assessment proceedings, the assessee has filed the loan confirmation letters of the loan creditors, which ... even on the remaining parties. The ld. CIT(Appeals) has simply dismissed the appeal of the assessee by passing a very cryptic and non-speaking order. Now the issue before us is whether the assessee has duly discharged his burden by filing the aforesaid evidences before the authorities

Bharatkumar Nathubhai Patel, Valsad vs. Income Tax Officer, Ward - 1, Valsad

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

ITA 698/SRT/2023[2011-12]Status: DisposedITAT Surat20 Dec 2023AY 2011-12

Bench: Shri Pawan Singh(Physical Hearing) Bharatkumar Nathubhai Patel, I.T.O., 704, Rushikesh Appartment, Tithal Ward-1, Vs. Road, Valsad (Gujarat)-396001. Valsad. Pan No. Asopp 2041 C Appellant/ Assessee Respondent/ Revenue

Section 142(1)Section 144Section 148Section 254(1)

appeal was not served upon the assessee. The ld. AR of the assessee further submits that the ld. CIT(A) passed a non-speaking order without discussing the merit of the case. 3. On the other hand, the learned Senior Departmental Representative (ld. Sr. DR) for the revenue supported ... appeal before the ld. CIT(A). The action of Assessing Officer was upheld by the ld. CIT(A) in ex parte proceedings and non-speaking order. In my view, the substantial right of assessee is involved in the present appeal, therefore, keeping in view the principle of natural justice

Vrundavan Restaurant, Surat vs. Income Tax Officer, Ward - 1(2)(1) (New) Ward-1(2)(5), Vadodara (Old), Surat

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

ITA 683/SRT/2023[2009-10]Status: DisposedITAT Surat19 Dec 2023AY 2009-10

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Vrundavan Restaurant, I.T.O., (1)-U-2, Ashirwad Square, Udhna Ward-1(2) (1), Surat- Vs. Magdalla Road, Surat 395007- New, New, (2)- 39/1, 4Th Floor, Vaibhav Ward 1(2)(5), Vadodara- Residency, Arunday Crossword Circle Old. Alkapuri, Alkapuri, Vadodara-390007 – Old. Pan No. Aagfv 8310 G Appellant/ Assessee Respondent/ Revenue

Section 147Section 148Section 250(6)Section 254(1)Section 41(1)Section 68

parte order without giving fair and reasonable opportunity to the assessee. The ld. CIT(A) confirmed the finding of Assessing Officer in a non-speaking order. Order 2 Vrundavan Restaurant Vs ITO of ld. CIT(A) is not in consonance with the mandate of Section 250(6) of the Income

Shri Lokendra Panwar, Indore vs. The PCIT (1), Indore

In the result, appeal of the assessee is allowed

ITA 185/IND/2023[2018-19]Status: DisposedITAT Indore14 Dec 2023AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Lokendra Panwar Pcit (1) 8 B Chandra Nagar, A.B. Indore Vs. Road, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Achpp2073R Assessee By Shri S.S. Solanki, Ar Revenue By Ms. Simran Bhullar Cit- Dr Date Of Hearing 31.10.2023 Date Of Pronouncement 14.12.2023

Section 142(1)Section 143Section 143(3)Section 263Section 57(1)

issue for which the limited scrutiny under CASS was taken up. Thus, Ld. DR has submitted that the order of the AO is non-speaking order and nothing is mentioned about the record which was filed by the assessee or examined by the AO on this issue. Even the assessee

Dilip Bhikhubhai Chauhan, Surat vs. Income Tax Officer, Ward-3(2)(2), Surat

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

ITA 509/SRT/2023[2011-12]Status: DisposedITAT Surat28 Nov 2023AY 2011-12

Bench: Shri Pawan Singh(Hybrid Hearing) Dilip Bhikhubhai Chauhan, I.T.O., Devkrupa Society, Opp. Dholakiya Ward-3(2)(2), Vs. Garden, Katargam, Surat-395004. Aayakar Bhavan, Majura Pan No. Aaopc 8463 B Gate, Surat. Appellant/ Assessee Respondent/ Revenue

Section 144Section 254(1)

Representative (ld. AR) of the assessee submits that the ld. CIT(A) dismissed the appeal of assessee in ex parte order by passing non-speaking order. The ld. AR of the assessee submits Dilip Bhikhubahi Chauhan Vs ITO that though the assessee was not allowed adequate opportunity before passing

Ashish Sharma, Gopal Pura Bye - Pass Jaipur vs. Income Tax Officer, Statue Circle, Jaipur

In the result, appeal of the assessee is allowed

ITA 586/JPR/2023[2009-10]Status: DisposedITAT Jaipur28 Nov 2023AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri S.L. Poddar (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT) a

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 292BSection 69A

Assessing Officer, the reasons recorded are defective and sanction granted u/s 151(2) is unlawful." Order of the Learned CIT(A) is a non-speaking order without considering the submissions made by the assessee. The Learned CIT(A) has passed the order totally ignoring the submissions of the assessee