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“reasoned order”

Natural JusticeReasoned OrderReasoned Order2,067 judgments

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

Leading authorities on reasoned 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.

ACIT v. Serajuddin & Co.
454 ITR 312 · 2023 · High Court
580
citing judgments

Approval under Section 153D of the Income Tax Act is mandatory for assessment orders in search cases. While elaborate reasons for approval are not required, the approving authority must provide some indication that it has examined the draft orders and found them to meet the requirements of law.

CIT v. Virgo Marketing (P) Ltd.
171 Taxmann 156 · 2008 · High Court
384
citing judgments

The assessment order must clearly specify the reason for initiating penalty proceedings under Section 271(1)(c) and explicitly state whether it is for concealment of income or furnishing inaccurate particulars. Failure to identify the specific limb under which penalty is initiated renders the penalty unsustainable.

V.M.Salgaocar & Bros.(P) Ltd. v. CIT
243 ITR 383 · 2000 · Supreme Court
189
citing judgments

An order by the Supreme Court dismissing a Special Leave Petition (SLP) at the threshold without detailed reasons does not constitute a declaration of law or a binding precedent. Such dismissal in limine offers no legal assistance.

Commissioner of Income-tax (Central) Nagpur v. Premkumar Arjundas Luthra (HUF)
69 Taxmann.com 407 · 2016 · High Court
159
citing judgments

The Commissioner (Appeals) cannot dismiss an appeal for non-prosecution; the law does not empower them to do so. The appeal must be decided on merits and in writing, stating points for determination, decision, and reasons.

CIT v. Nirma Chemical Works Ltd.
309 ITR 67 · 2009 · High Court
149
citing judgments

An assessment order is not erroneous or prejudicial under Section 263 merely because it is silent on a claim or lacks explicit reasons for its acceptance. Revision under Section 263 is impermissible if the Assessing Officer has taken a plausible view, even if the PCIT holds a different opinion.

PCIT v. Premkumar Arjundas Luthra
279 CTR 614 · High Court
132
citing judgments

The Commissioner of Income Tax (Appeals) is duty-bound to dispose of appeals on their merits, even when proceeding ex-parte. This requires framing points for determination, providing detailed reasoning for the decision, and affording the assessee a reasonable opportunity of being heard, as mandated by Section 250(6).

Home Finders Housing Ltd. v. Income-tax Officer Ward 2(3), Chennai
93 Taxmann.com 371 · 2018 · High Court
125
citing judgments

Failure by the Assessing Officer to supply reasons for reassessment or dispose of the assessee's objections, as required by the GKN Driveshafts procedure, is a procedural irregularity that does not render the reassessment order void. Such non-compliance can be cured by remitting the matter back to the Assessing Officer for proper adherence to the procedure.

Judgments citing reasoned order

Boddu Sai Baba, Tadepalligudem vs. Income Tax Officer, Ward-1, Tadepalligudem

ITA 571/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.571/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Boddu Sai Baba, Vs. Income Tax Officer, Tadepalligudem. Ward-1, Pan: Ahspb0015F Tadepalligudem. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 26/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 27/12/2023, For The Assessment Year 2018-19. The Assessee Has 2 Boddu Sai Baba Vs. Ito

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 44ASection 80T

were made by the AO. We would mince no words in observing that the order passed by the CIT(A) falls short of a reasoned order, wherein he has failed to deal with all the specific grounds based on which the impugned order of assessment was 10 Boddu Sai Baba

Income Tax Officer, Mumbai vs. Nariman Bhavan Premises Co Op Society Ltd, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 3659/MUM/2023[2015-16]Status: DisposedITAT Mumbai02 Dec 2025AY 2015-16

Bench: Hon‟Ble Justice (Retd.) C. V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2015-16 Income Tax Officer, Mumbai Nariman Bhavan Premises Co Op Room No. 118, 1St Floor, Society Ltd. G Block, Kautilya Bhavan, Vs. 227 Backbay Reclamation, Bandra Kurla Complex (E), Nariman Point, Mumbai – 400021. Mumbai – 400051. [Pan: Aajn0320J] (Appellant) (Respondent) For Assessee : Shri K. Gopal / Om Kandalkar For Revenue : Ms. Nidhi Agarwal, Sr. Dr (Virtually Present) Date Of Hearing : 02-12-2025 Date Of Pronouncement : 02-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) - National Faceless Appeal Centre (Nfac), Delhi [„Ld. Cit(A)‟], Dated 14-08-2023, Pertaining To Assessment Year (Ay) 2015-16. 2. At The Outset, It Is Noted That This Is A Recalled Matter Wherein Co-Ordinate Bench Vide Its Order Dated 22.09.2025 In Ma No. 244/M/2024 Has Recalled The Earlier Order Dated 08.05.2024 & The Matter Has Now Come Up For Adjudication Before Us.

For Appellant: Shri K. Gopal / Om KandalkarFor Respondent: Ms. Nidhi Agarwal, Sr. DR
Section 3Section 80Section 80PSection 80P(1)Section 80P(2)(d)

judicial precedence. We find the CIT(A) has considered the facts, submissions and relied on the judicial decisions and haspassed a conclusive and reasoned order. Accordingly, we do not find any infirmity in the order of the CIT(A) on the disputed issues and uphold the same and dismiss