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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

Dy. C.I.T. Cir-.2, Nagpur vs. Shri Govinddas Goverdhan Daga, Nagpur

In the result, appeal filed by the Revenue for A

ITA 614/NAG/2016[2013-14]Status: DisposedITAT Nagpur05 Feb 2025AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 35(1)Section 35(1)(ii)

Bench for not disturbing the impugned order passed by the learned CIT(A), as the order passed by the learned CIT(A) is a reasoned order. 7. We have heard the arguments of the learned Departmental Representative, perused the material available on record and gone through the orders ... learned CIT(A) treating the agricultural income as non–genuine is impregnable and hence we decline to interfere as the same is a well- reasoned order and does not warrant any interference. Accordingly, grounds no.3 and 4, are dismissed. 14. In the result, appeal filed by the assessee

Shri Go0Vinddas Govardhandas Daga, Nagpur vs. A.C.I.T. Circle 2, Nagpur

In the result, appeal filed by the Revenue for A

ITA 601/NAG/2016[2013-14]Status: DisposedITAT Nagpur05 Feb 2025AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 35(1)Section 35(1)(ii)

Bench for not disturbing the impugned order passed by the learned CIT(A), as the order passed by the learned CIT(A) is a reasoned order. 7. We have heard the arguments of the learned Departmental Representative, perused the material available on record and gone through the orders ... learned CIT(A) treating the agricultural income as non–genuine is impregnable and hence we decline to interfere as the same is a well- reasoned order and does not warrant any interference. Accordingly, grounds no.3 and 4, are dismissed. 14. In the result, appeal filed by the assessee

Bharat Utkarsh Sewa Sansthan, Janjgir-Champa vs. Income Tax Officer (Exemption), Bilaspur

In the result, appeal filed by the assessee society is dismissed in terms of the aforesaid observations

ITA 423/RPR/2024[2018-19]Status: DisposedITAT Raipur31 Jan 2025AY 2018-19

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No.423/Rpr/2024 "नधा"रण वष" / Assessment Year : 2018-19 Bharat Utkarsh Sewa Sansthan Bharat Utkarsh College Of Education C/O. R.C. Pandey, P.O-Sarkhon Naila, District: Janjgir Champa Pan: Aacab0445A .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer (Exemption) Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri G.S. Agrawal, CAFor Respondent: Smt. Tarannum Verma, Sr. DR
Section 10Section 143(2)Section 143(3)

10A/10AA of the Act. 23. Be that as it may, I am of a firm conviction that as no infirmity arises from the well-reasoned orders of the lower authorities who had rightly assessed the assessee society at the income returned by it, therefore, I uphold the same. Thus

M/S. Slk Software Private Limited, Bengaluru vs. The Assistant Commissioner of Income-Tax, Special Range-6N, Bangalore

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

ITA 933/BANG/2023[2018-19]Status: DisposedITAT Bangalore31 Jan 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharath L, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 14A

available on record. The ld. AR before us fairly submitted that the order passed by the ld. CIT-A is non-speaking and non-reasoned order and therefore, the matter should be remitted back . ITA Nos. 932 & 933/Bang/2023 Page 11 of 17 to the file of the learned ... absence of the assessee. The CIT(A) is expected to adjudicate the issues based on the material available on record and provide a reasoned order. the relevant portion of the Judgment is reproduced as under: “In view of the above facts and legal ratio laid by the Hon'ble Mumbai

M/S. Slk Software Private Limited, Bengaluru vs. The Assistant Commissioner of Income-Tax, Special Range-6, Bangalore

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

ITA 932/BANG/2023[2017-18]Status: DisposedITAT Bangalore31 Jan 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Bharath L, C.AFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 14A

available on record. The ld. AR before us fairly submitted that the order passed by the ld. CIT-A is non-speaking and non-reasoned order and therefore, the matter should be remitted back . ITA Nos. 932 & 933/Bang/2023 Page 11 of 17 to the file of the learned ... absence of the assessee. The CIT(A) is expected to adjudicate the issues based on the material available on record and provide a reasoned order. the relevant portion of the Judgment is reproduced as under: “In view of the above facts and legal ratio laid by the Hon'ble Mumbai

Smt. Liz Hemangbhai Bhatt, Ahmedabad vs. The Income Tax Officer, Ward-14(2), Ahmedabad

In the result, the appeal filed by the assessee is dismissed for non- prosecution

ITA 2426/AHD/2016[2008-0]Status: DisposedITAT Ahmedabad30 Jan 2025

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.2426/Ahd/2016 िनधा"रण वष" /Assessment Year : 2008-09 Smt.Liz Hemangbhai Bhatt The I.T.O. Ward 14 (2) बनाम/ 301, A Devprit Apartment Ahmedabad V/S. Nr.Bodakdev Cross Road Ahmedabad "थायी लेखा सं./Pan: Adtpb 9174 C (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : -None- Revenue By : Shri A.P. Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 28/01/2025 घोषणा की तारीख /Date Of Pronouncement: 30/01/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: The Present Appeal Has Been Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-5, Ahmedabad [Hereinafter Referred To As “Cit(A)”] Dated 09.08.2016, For The Assessment Year 2008-09, Arising Out Of The Reassessment Order Passed By The Assessing Officer, Ward- 14(2), Ahmedabad (Hereinafter Referred To As “Ao”), Under Section 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

For Appellant: -None-For Respondent: Shri A.P. Singh, CIT-DR
Section 147Section 68Section 69

neither the assessee nor any authorized representative appeared before us. 7. The Departmental Representative (DR) submitted that the CIT(A) has passed a well-reasoned order, and in the absence of any representation from the assessee’s side, the appeal should be dismissed for non-prosecution. 8. We considered ... appear and prosecute the appeal, the same may be dismissed for non-prosecution. Accordingly, we find no reason to interfere with the well-reasoned order of CIT(A), who has already granted substantial relief. 14. In the result, the appeal filed by the assessee is dismissed for non- prosecution. Order

Mr. Kallappa Shadakshari, Tiptur vs. Income Tax Officer, Ward-1, Tiptur

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

ITA 108/BANG/2025[2016-17]Status: DisposedITAT Bangalore30 Jan 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadavassessment Years: 2016-17

For Appellant: Shri M.R Venkatesh Babu, C.AFor Respondent: Smt. Neha Sahay, JCIT

fresh adjudication. The CIT(A) is directed to reconsider the assessee’s submissions in light of relevant judicial precedents and provide a reasoned order addressing all legal aspects. Hence the ground of appeal of the assessee is allowed for statistical purposes. 12. In the result, the appeal filed

DCIT, Central Circle-2, Faridabad vs. Peakwood Reality Pvt.Ltd., Gurgaon

ITA 89/DEL/2023[2012-13]Status: DisposedITAT Mumbai30 Jan 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2012-13 Dy. Cit Central Circle-Ii, M/S Peakwood Reality Pvt. Ltd., New Cgo Complex, Block- ‘B’, 3Rd Shop No. 6, 2Nd Floor, Jagdamba Vs. Floor, Nh-Iv, Faridabad, Palace, Near Gurgaon Dreamz Mall, Haryana-121001. Old Railway Road, Gurgaon-122001. Pan No. Aacce 1245 J Appellant Respondent

For Appellant: Mr. Gautam Jain (Virtually Present)For Respondent: Mr. R.A. Dhyani, CIT-DR

High Court, we find no justification for interfering with the well the High Court, we find no justification for interfering with the well reasoned order of the CIT( reasoned order of the CIT(A). Accordingly, the ground raised in ground raised in present appeal stands dismissed. present appeal stands dismissed

Sri Ram Constructions, Patna vs. ITO, Ward- 6 (5), Patna

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

ITA 353/PAT/2024[2015-16]Status: DisposedITAT Patna28 Jan 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 145(3)Section 250Section 43C

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

Link Commercial Pvt. Ltd., Kolkata vs. I.T.O., Ward - 1(4), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1368/KOL/2024[2011-2012]Status: DisposedITAT Kolkata28 Jan 2025AY 2011-2012

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.1368/Kol/2024 Assessment Year: 2011-12 Link Commercial Pvt. Ltd...………........………………....Appellant C/O Subash Agarwal & Associates, Advocate Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Aabcl4354L] Vs. Ito, Ward-1(4), Kolkata…….……….…............................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Assessee. Shri Pradip Biswas, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : October 30, 2024 Date Of Pronouncing The Order : January 28, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 10.06.2024 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’) Pertaining To Assessment Year 2011-12. 2. In This Appeal, The Assessee Challenged The Validity Of Reopening Proceedings U/S 147/148 Of The Act & The Addition Of Rs.2,02,00,000/- Made U/S 68 Of The Act As Unexplained Cash Credit. 3. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income On 30.03.2012 By Declaring A Total Income Of Rs.35,061/-. The Return Was Processed U/S 143(1) Of The Act. Subsequent To That, The Case Of The Assessee Was Reopened U/S 147 Of The Act & A Notice U/S 148 Of The Act Was Issued On 31.03.2018 After Obtaining Prior Approval

Section 133(6)Section 143(1)Section 147Section 148Section 250Section 68

details of the sale of shares transactions and any other documents to prove its case. The Assessing Officer shall pass a reasoned order in accordance with law after considering all submissions, evidences or explanations given by the assessee before him. 8. In terms of the above, the appeal

Syed Asim, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 1888/CHNY/2024[2017-18]Status: DisposedITAT Chennai27 Jan 2025AY 2017-18

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.1885, 1886, 1887 & 1888/Chny/2024 िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 Syed Asim, The Income Tax Officer, New No.4, Old No.2, Chandralekha Vs. Non Corporate Ward-3(3), Muthusamy Mudaliar Street, Chennai. Nungambakkam, Chennai – 600 034. [Pan: Aveps 3501P]

For Appellant: Shri K. Ravi, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 44A

submitted any evidence in support of his contention either before A.O or before Ld. CIT(A) and the Ld. CIT(A) has passed reasoned order and therefore, order of Ld. CIT(A) may be confirmed. 6. We have heard the rival submissions, and perused the materials available on record

Syed Asim, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 1887/CHNY/2024[2016-17]Status: DisposedITAT Chennai27 Jan 2025AY 2016-17

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.1885, 1886, 1887 & 1888/Chny/2024 िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 Syed Asim, The Income Tax Officer, New No.4, Old No.2, Chandralekha Vs. Non Corporate Ward-3(3), Muthusamy Mudaliar Street, Chennai. Nungambakkam, Chennai – 600 034. [Pan: Aveps 3501P]

For Appellant: Shri K. Ravi, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 44A

submitted any evidence in support of his contention either before A.O or before Ld. CIT(A) and the Ld. CIT(A) has passed reasoned order and therefore, order of Ld. CIT(A) may be confirmed. 6. We have heard the rival submissions, and perused the materials available on record

Syed Asim, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 1886/CHNY/2024[2015-16]Status: DisposedITAT Chennai27 Jan 2025AY 2015-16

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.1885, 1886, 1887 & 1888/Chny/2024 िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 Syed Asim, The Income Tax Officer, New No.4, Old No.2, Chandralekha Vs. Non Corporate Ward-3(3), Muthusamy Mudaliar Street, Chennai. Nungambakkam, Chennai – 600 034. [Pan: Aveps 3501P]

For Appellant: Shri K. Ravi, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 44A

submitted any evidence in support of his contention either before A.O or before Ld. CIT(A) and the Ld. CIT(A) has passed reasoned order and therefore, order of Ld. CIT(A) may be confirmed. 6. We have heard the rival submissions, and perused the materials available on record

Syed Asim, Chennai vs. ITO, Ncw-3(3), Chennai

In the result, all the four appeals filed by the assessee are partly allowed

ITA 1885/CHNY/2024[2014-15]Status: DisposedITAT Chennai27 Jan 2025AY 2014-15

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.1885, 1886, 1887 & 1888/Chny/2024 िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 Syed Asim, The Income Tax Officer, New No.4, Old No.2, Chandralekha Vs. Non Corporate Ward-3(3), Muthusamy Mudaliar Street, Chennai. Nungambakkam, Chennai – 600 034. [Pan: Aveps 3501P]

For Appellant: Shri K. Ravi, Advocate &For Respondent: Ms. R. Anitha, Addl. CIT
Section 131Section 133ASection 143(3)Section 147Section 148Section 44A

submitted any evidence in support of his contention either before A.O or before Ld. CIT(A) and the Ld. CIT(A) has passed reasoned order and therefore, order of Ld. CIT(A) may be confirmed. 6. We have heard the rival submissions, and perused the materials available on record

International Hospital Ltd. (Before Amalgamation M/S Escorts Heart and Super Specialty Institute Ltd), New Delhi vs. ITO, Ward-8(3), New Delhi

The appeals of the assessee are allowed for statistical

ITA 5957/DEL/2019[2013-14]Status: DisposedITAT Delhi27 Jan 2025AY 2013-14

Bench: Ms. Madhumita Roy&

For Respondent: Ms. Monika Singh, CIT, DR
Section 12ASection 80G

prakash Charitable Trust 4. Thus, we dispose of the matters by remitting the issues to the file of the Ld. CIT(E) for passing reasoned orders upon granting an opportunity of being heard to the assessee and upon considering the evidences on record or any other evidence which the assessee ... chose to file at the time of hearing of the matter. The Ld. CIT(E) is directed to pass a reasons order. 4. Both the appeals of the assessee are allowed for statistical purposes. Order pronounced in the open court on 06.06.2025 Sd/- Sd/- (Madhumita Roy) (Khettra Mohan Roy) JUDICIAL

Zim Laboratories Limited, Nagpur vs. Assistant Commissioner of Income Tax Central Circle -2(1), Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 118/NAG/2018[2013-2014]Status: DisposedITAT Nagpur23 Jan 2025AY 2013-2014

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132(1)Section 143(1)Section 153Section 153A

find that the findings of the learned CIT(A) 8 Zim Laboratories Ltd. on both the issues are self–explanatory and a well–reasoned order and consequent upon such findings of the learned CIT(A), we find no scope to tinker with the impugned order on both the issues. Accordingly

Zim Laboratories Limited, Nagpur vs. Assistant Commissioner of Income Tax Central Circle -2(1), Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 117/NAG/2018[2009-2010]Status: DisposedITAT Nagpur23 Jan 2025AY 2009-2010

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132(1)Section 143(1)Section 153Section 153A

find that the findings of the learned CIT(A) 8 Zim Laboratories Ltd. on both the issues are self–explanatory and a well–reasoned order and consequent upon such findings of the learned CIT(A), we find no scope to tinker with the impugned order on both the issues. Accordingly

Zim Laboratories Limited, Nagpur vs. Assistant Commissioner of Income Tax Central Circle -2(1), Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 116/NAG/2018[2008-2009]Status: DisposedITAT Nagpur23 Jan 2025AY 2008-2009

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Sandipkumar Salunke
Section 132(1)Section 143(1)Section 153Section 153A

find that the findings of the learned CIT(A) 8 Zim Laboratories Ltd. on both the issues are self–explanatory and a well–reasoned order and consequent upon such findings of the learned CIT(A), we find no scope to tinker with the impugned order on both the issues. Accordingly

Income Tax Officer, Ward-1, Shillong vs. Achula Darneichong Sailo, Shillong

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

ITA 119/GTY/2023[2013-14]Status: DisposedITAT Guwahati22 Jan 2025AY 2013-14

Bench: Sri Manomohan Das & Sri Rakesh Mishra

Section 10(26)Section 142(1)Section 147Section 148Section 250Section 44A

section 10(26) of the Act. Hence, since the provisions of section 250(6) of the Act have not been followed and neither a reasoned order has been passed nor the Ld. AO was granted any opportunity of being heard. Merely because the assessee is a member of the scheduled

Vasudevan Lash, Kozhikode vs. The ITO Ward (1), Kozhikode

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

ITA 652/COCH/2023[2011-12]Status: DisposedITAT Cochin22 Jan 2025AY 2011-12

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Radhakrishnan K, AdvocateFor Respondent: Smt.Leena Lal, Sr.AR
Section 250(6)

assessee to represent the case before the Ld.CIT(A). The learned Counsel further contended that the order of the Ld.CIT(A) is not a reasoned order and hence an opportunity of being heard may kindly be granted to the assessee. 2 ITA No.652/Coch/2023. Sri.Vasudevan Lash. 3. The learned Departmental Representative