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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

Sh.Sudesh Verma, Dehradun vs. ITO, W-1(2)(4), Dehradun

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

ITA 86/DDN/2024[2017-18]Status: DisposedITAT Dehradun28 Jul 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 133(6)Section 250Section 282Section 69A

order though he, as per provisions of section 250(6) of the Act, is obliged to dispose of the appeal in writing with well-reasoned order on each point of determination arisen for his consideration. It is evident from the perusal of section

Parisara Abhivrudhi Foundation, Bangalore vs. Commissioner of Income Tax (Exemptions), Bangalore

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

ITA 913/BANG/2025[NA]Status: DisposedITAT Bangalore28 Jul 2025

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Dr. N. Suresh, CAFor Respondent: Shri Sridhar E., CIT(DR)(ITAT), Bengaluru
Section 12Section 12ASection 13(3)Section 80Section 80G

issue show cause notice to the assessee, if she does not agree with the submission of the assessee and then pass the reasoned order. Accordingly this appeal is allowed for statistical purposes. 13. The second ITA number 913/B/2025 is against the rejection of application for registration under section

Parisara Abhivrudhi Foundation, Bangalore vs. Commissioner of Income Tax(Exemptions), Bengaluru

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

ITA 912/BANG/2025[NA]Status: DisposedITAT Bangalore28 Jul 2025

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Dr. N. Suresh, CAFor Respondent: Shri Sridhar E., CIT(DR)(ITAT), Bengaluru
Section 12Section 12ASection 13(3)Section 80Section 80G

issue show cause notice to the assessee, if she does not agree with the submission of the assessee and then pass the reasoned order. Accordingly this appeal is allowed for statistical purposes. 13. The second ITA number 913/B/2025 is against the rejection of application for registration under section

Income Tax Officer 7(3)(1), Mumbai vs. Palmon Impex Pvt. Ltd., Mumbai

In the result, both the appeals filed by the assessee and revenue are dismissed in above terms

ITA 2939/MUM/2025[2011-12]Status: DisposedITAT Mumbai28 Jul 2025AY 2011-12

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhanpalmon Impex Pvt. Ltd. Ito-7(3)(1), 9, Janata Indudstries Compound, Aayakar Bhavan, M. K. Road, 162, S. B. Marg, Lower Parel (W), Vs. Mumbai-400 020 Mumbai-400013 Pan: Aaecm3977F

Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

assessing authority and the submission made by the parties, the judgment of the Delhi High Court does not have binding precedent being not a reasoned order deciding the issue in question. It also lacks persuasive effect being not deciding the issue involved.” 19. Thus, it can be culled out from

Palmon Impex Pvt Ltd, Mumbai vs. Income Tax Officer- 7(3)(1), Mumbai

In the result, both the appeals filed by the assessee and revenue are

ITA 2561/MUM/2025[2011-12]Status: DisposedITAT Mumbai28 Jul 2025AY 2011-12

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

assessing authority and the submission made by the parties, the judgment of the Delhi High Court does not have binding precedent being not a reasoned order deciding the issue in question. It also lacks persuasive effect being not deciding the issue involved. 19. Thus, it can be culled out from

Vijay Israni, Delhi vs. DCIT, Central Circle-6, Delhi

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

ITA 752/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishra

Section 143(3)Section 147Section 148Section 153CSection 68

order though he, as per provisions of section 250(6) of the Act, is obliged to dispose of the appeal in writing with well-reasoned order on each point of determination arisen for his consideration. It is evident from 4 Vijay Israni the perusal of section

Promotional Club, New Delhi vs. ITO, Ward-28(1), Delhi

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

ITA 748/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Jul 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.748 /Del./2025, A.Y. 2017-18 Promotional Club Income Tax Officer, D-815, New Friends Colony, Ward-28(1), Civic Centre, New Delhi - 110025 Vs. Minto Road, New Delhi Pan: Aajfp4348R (Appellant) (Respondent) Appellant By None Respondent By Shri Om Prakash, Sr. Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 28/07/2025 Order Per Avdhesh Kumar Mishra, Am

Section 115BSection 234BSection 250(4)Section 250(6)Section 68

order though he, as per provisions of section 250(6) of the Act, is obliged to dispose of the appeal in writing with well- reasoned order on each point of determination arisen for his consideration. It is evident from the perusal of section

Nisha Data Com Limited, Rourkela vs. Income Tax Officer Ward-3 Rourkela, Rourkela

In the result, both the appeals filed for AY 2011-12 and AY 2012-

ITA 174/CTK/2025[2012-13]Status: DisposedITAT Cuttack25 Jul 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133BSection 144Section 250Section 40

examining the records while disposing of the appeal. The Ld. CIT(A) has neither adjudicated upon various grounds of appeal nor has passed a reasoned order for arriving at the decision, as is required u/s 250(6) of the Act. We further note that in Ajji Basha

Nisha Data Com Limited, Rourkela vs. Income Tax Officer Ward-3 Rourkela, Rourkela

In the result, both the appeals filed for AY 2011-12 and AY 2012-

ITA 173/CTK/2025[2011-12]Status: DisposedITAT Cuttack25 Jul 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133BSection 144Section 250Section 40

examining the records while disposing of the appeal. The Ld. CIT(A) has neither adjudicated upon various grounds of appeal nor has passed a reasoned order for arriving at the decision, as is required u/s 250(6) of the Act. We further note that in Ajji Basha

DCIT, Circle 3(1), Visakhapatnam vs. Vikas Kumar Chhajer, Vizianagaram

ITA 212/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2022-23

Bench: Us:

Section 132Section 143(2)Section 143(3)Section 68

impugned addition made by the A.O. under Section 68 of the Act. 22 Vikas Kumar Chhajer 20. Resultantly, finding no infirmity in the reasoned order of the CIT(A), we find no substance in the appeal filed by the Revenue, which, thus, being devoid and bereft of any substance

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. Aqua Fiber Indsutries, Panchkula

ITA 508/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh25 Jul 2025AY 2017-18

Bench: the Ld. CIT(A). The Ld. CIT(A), after considering the detailed submissions and supporting evidences furnished by the assessee, deleted the additions.4. The Revenue's challenge is confined to the CIT(A)'s acceptance of additional evidence allegedly in violation of Rule 46A. The merits of the deletion have not been independently challenged.

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Smt. Meenakshi Vohra, CIT, DR
Section 133(6)Section 143(3)

shown that such evidence was considered without opportunity. On the contrary, the Ld. CIT(A) has duly examined the evidence and passed a reasoned order. We also cannot overlook that the Revenue has accepted all sales and the book results. Once purchases have been accounted for, payments made through banking

Bigstar Hotels Resorts Pvt. Ltd., New Delhi vs. ITO Ward 5(1), New Delhi

ITA 3351/DEL/2024[2020-21]Status: DisposedITAT Delhi25 Jul 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(3)Section 250

facts and in the circumstances of the case, the Learned Commissioner of Income Tax (A) ("Ld. CIT(A)") vide a non-speaking and un-reasoned order dated 09.07.2024 u/s.250 of the Income-tax Act, 1961 ("Act") (hereinafter referred to as "1st impugned order") has erred in sustaining the addition made

DCIT, New Delhi vs. M/S Gen X Commodities (P) Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 3560/DEL/2016[2010-11]Status: DisposedITAT Delhi25 Jul 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Amitabh Shukla[Assessment Year : 2010-11] Dcit Vs M/S. Gen X Commodities (P) Ltd., Central Circle-29 Fa-45, Shivaji Enclave New Delhi New Delhi-110027 Pan-Aaaca2303H Appellant Respondent Shri Jitender Singh, Cit Dr Revenue By Assessee By Shri Ved Jain, Adv. & Shri Ayush Garg, Ca Date Of Hearing 26.06.2025 Date Of Pronouncement 25.07.2025

Section 14ASection 2(22)(e)Section 250(6)

case and group case as pointed out on behalf of the assessee. We thus see no reason to interfere with the well-reasoned order of CIT(A) and uphold the finding of the Ld. CIT(A) and accordingly, dismiss the ground Nos.(e) & (f) raised by the Revenue. 21. Ground

Satbichar Distributors Private Limited, Kanpur vs. ITO, Ward 3(1), Kolkata

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

ITA 448/KOL/2025[2013-14]Status: DisposedITAT Kolkata24 Jul 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 250

examining the records while disposing of the appeal. The Ld. CIT(A) has neither adjudicated upon various grounds of appeal nor has passed a reasoned order for arriving at the decision, as is required u/s 250(6) of the Act. We further note that in Ajji Basha

Deesha Trade Endeavours Pvt Ltd, Siliguri vs. ITO Ward 1(3), Siliguri

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

ITA 1113/KOL/2025[2018-19]Status: DisposedITAT Kolkata24 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1113/Kol/2025 Assessment Year: 2018-19 Deesha Trade Endeavours Pvt. Ltd….…………………....Appellant Dhruvatara, Opp Bsnl Residential Complex, Sukanta Sarani, New Milan Pally, Siliguri-734005. [Pan: Aabcd8122A] Vs. Ito, Ward-1(3), Siliguri…………..…..…..………………….…..... Respondent Appearances By: Shri Sujit Basu, Adv., Rajib Mukherjee, Adv., Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 24, 2025 Date Of Pronouncing The Order : July 24, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 26.03.2025 Passed By The National Faceless Appeal Centre [In Short Cit(A)] Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2018–19 Declaring Total Income Of ₹6,68,970. The Case Was Selected For Scrutiny Under Cass & Accordingly, Notice Under Section 143(2) Was Issued. During The Course Of Assessment, It Was Noticed That The Assessee Had Received Unsecured Loan Aggregating ₹5,43,50,000 In Its Books Of Accounts & There Was Also Underreporting Of Income To The Extent Of ₹2,500. Considering The Lack Of Satisfactory Explanation, The Ao Completed The Assessment Under Section 143(3) Of The Act On 23.04.2021, Assessing The Total

Section 143(2)Section 143(3)Section 250Section 68

liberty to obtain a remand report from the AO, if required, and shall pass a speaking and reasoned order after giving due opportunity to the assessee. In view of the above the appeal of the assessee is allowed for statistical purposes, the matter is restored to the file

Assistant Commissioner of Income Tax, Central Circle - 2(4), Bengaluru, Bangalore vs. M/S Mrk Gold LLP, Bangalore

ITA 1026/BANG/2025[2020-21]Status: DisposedITAT Bangalore24 Jul 2025AY 2020-21

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2020-21

For Appellant: Shri. Narendra Kumar J Jain, AdvocateFor Respondent: Shri. R. Rajamanohar, JCIT(DR)(ITAT), Bangalore
Section 115BSection 133ASection 143(1)Section 69B

above order of the CIT(A), we do not find any infirmity in the order of the CIT(A) and he has passed a reasoned order. We further note that the case laws relied by the CIT(A) as well as the ld.AR of the assessee noted supra, supports

Shafiq Ahmed, Mumbai vs. Deputy Commissioner of Income Tax Circle 41(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 3008/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Jul 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2017-18 Shafiq Ahmed, Dy. Cit Circle-41(1)(1), Flat No. 322, 3Rd Floor, Building Kautilya Bhavan, Bkc, Bandra Vs. No. 1 Om Sai Ekta (Sra), (East), Society, Cts No. 216, Gillbert Mumbai-400051. Hill Road, Andheri (W), Mumbai-400058. Pan No. Aowpa 3264 Q Appellant Respondent

For Appellant: Mr. Pravin Salunkhe, Sr. DRFor Respondent: Mr. Hasan Khan, Virtually Present
Section 148Section 148A

obligate the authority to pass a speaking Section 250(6) of the Act, obligate the authority to pass a speaking and reasoned order, even in the absence of participation by the and reasoned order, even in the absence of participation by the and reasoned order, even in the absence

Girish Narpatchand Kanungo, Mumbai vs. Income Tax Officer 19(1)(3), Mumbai

In the result, the appeal of the assesse bearing ITA No

ITA 1233/MUM/2025[2011-12]Status: DisposedITAT Mumbai24 Jul 2025AY 2011-12

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeegirish Narpatchand Kanungo Vs Income-Tax Officer, 19(1)(3), 2Nd Flat No.3, Floor, 5, Mumbai, 2Nd Ramnivas Building, Piramal Chamber, Parel Mumbai- Parsiwada Lane, Opp. V.P. 400012 Road, Police Station, Mumbai- 400 004 Pan: Aoapk9201M Appellant Respondent

For Appellant: Shri Pankaj JainFor Respondent: Shri Swapnil Choudhary – Sr AR
Section 139(1)Section 142(1)Section 143(3)Section 148Section 250

because the sellers and the canvassing agents have not been produced before them. We find that the order of the Tribunal is well a reasoned order taking into account all the facts before concluding that the purchases of Rs.1.33 crores was not bogus. No fault can be found with

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd), Mumbai vs. Assistant Commissioner of Income Tax Central Circle 8(1), Mumbai

In the result, the appeals filed by the assessee are

ITA 5423/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Jul 2025AY 2020-21
Section 115JSection 132Section 143(3)Section 153ASection 69A

No.2227/Mum/2024 and others Mahadhan Agritech Limited considering all the factors such as rationale, accounting treatment, recognition of intangible assets, etc. Thus, such a well-reasoned order cannot be ignored, much less be categorized as a colorable device as has been alleged by the department. 39. The ld. AR further addressed

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Limited ), Mumbai vs. Deputy Commissioner of Income Tax, Central Circle -8(1), Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3937/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

above, the ld. AR submitted that the NCLT has approved the scheme of arrangement treatment, recognition of intangible assets, etc. Thus, such a well-reasoned order cannot be ignored, much less be categorized as a colorable device as has been alleged by the department. 39. The ld. AR further addressed