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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

A V S Shiksha Evam Samajotthan Samiti, Sagar vs. Commissioner of Income Tax, Excemption, Bhopal

In the result the appeal is allowed for statistical purposes

ITA 178/JAB/2024[2024-25]Status: DisposedITAT Jabalpur28 Aug 2025AY 2024-25

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2024-25 Avs Shiksha Evam Samajotthan Vs. Commissioner Of Income Tax Samiti Sagar, Malthone Khurai, Sagar, (Exemption), Bhopal Madhya Pradesh Pan:Aafta9213L (Appellant) (Respondent) Assessee By: Sh. Dhiraj Ghai, Ca Revenue By: Sh. Shravan Kumar Meena, Cit Dr Date Of Hearing: 19.08.2025 Date Of Pronouncement: 28.08.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Learned Cit(Exemption) Passed On 11.11.2024 Rejecting The Application For Registration Of The Society Under Section 12A (1)(Ac)(Iii) Filed In Form 10Ab. The Grounds Of Appeal Are Under:- “1. Order Passed By Cit Exemption Bhopal Rejecting Application For Registration U/S 12Aa Ex Parte Is Bad In Law As It Was Passed In Complete Breach Of Principle Of Natural Justice. 2. The Ld. Commissioner Of Income Tax Exemption-Bhopal Erred In Law & On Facts In Rejecting Application Seeking A V S Shiksha Evam Samajotthan Samiti Approval/Registration U/S 12Aa Of The Act, Without Appreciating Facts & Law Of The Case Properly. 3. The Rejection Of Registration U/S. 12A (1) (Ac) (Iii) Of The Act Will Lead To Grave Financial Hardship & Hindrances In Its Charitable Activities & Accordingly, An Early Hearing Of The Captioned Appeal Be Granted. 4. The Appellant Also Prays That The Order Passed By The Ld. Cit(E) Be Quashed/Set Aside & The Appellant Should Be Granted A Fresh Opportunity & Matter Be Restored To Cit(E).”

For Appellant: Sh. Dhiraj Ghai, CAFor Respondent: Sh. Shravan Kumar Meena, CIT DR
Section 12A

should be issued to the assessee to make due compliance before the ld. CIT(Exemption) so that the ld. CIT(Exemption) could pass a reasoned order. 5. We have duly considered the facts and circumstances of the case. It is seen that the time period involved in the proceedings ... necessary compliances before the ld. CIT(Exemption) so that the ld. CIT(Exemption) may appreciate the facts of the case and pass a reasoned order, in accordance with law. 6. In the result the appeal is allowed for statistical purposes. Order pronounced on 28.08.2025 in the open Court. [KUL BHARAT

DCIT, CC-1(4), Ahmedabad vs. Goldmine Commodities Private Limited, Ahmedabad

In the result, the appeal filed by the Revenue is dismissed

ITA 1260/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad27 Aug 2025AY 2016-17

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1260/Ahd/2024 िनधा"रण वष" /Assessment Year : 2016-17 The Deputy Commissioner Goldmine Commodities Pvt. Ltd., Of Income Tax, बनाम/ Goldmine House, V/S. Central Circle-1(4), 4, Niranjan-Nirakar Society, Ahmedabad. Near Shreyas Railway Crossing, Ambawadi Ahmedabad-380007. (Gujarat) "थायी लेखा सं./Pan: Aaccg1295L अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri Rignesh Das, Cit-Dr Assessee By : Shri Kishor Goyal, Ar सुनवाई की तारीख/Date Of Hearing : 12/08/2025 घोषणा की तारीख /Date Of Pronouncement: 27/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Revenue Is Directed Against The Order Dated 25.04.2024 Of The Commissioner Of Income-Tax (Appeals) [Hereinafter Referred To As “The Cit(A)”] Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”] For Assessment Year 2016-17. The Acit, Circle-2(1)(1), Ahmedabad [Hereinafter Referred To As “Assessing Officer Or Ao”], Dcit Vs. Goldmine Commodities Pvt. Ltd. Assessment Year 2016-17

For Appellant: Shri Kishor Goyal, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 115JSection 143(3)Section 250Section 271(1)(c)Section 274Section 56(2)(viib)

method with NAV method merely on the basis of subsequent divergence between projections and actuals. We find no infirmity in the well-reasoned order of the CIT(A) warranting our interference. DCIT Vs. Goldmine Commodities Pvt. Ltd. Assessment Year 2016-17 22. In the result, the appeal filed