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“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

Reassessment proceedings are invalid if initiated based on documents already available on record without fresh tangible material, and if the sanction under section 151 is accorded mechanically, indicating non-application of mind.

M/s Sahara India (Farms) v. CIT & Anr.
300 ITR 403 · 2008 · Supreme Court
268
citing judgments

The requirement of statutory prior approval by a high-ranking authority, even if administrative, serves as an in-built protection against arbitrary exercise of power by the Assessing Officer. While such approval need not record elaborate reasoning, the approving authority has a heavy duty to ensure it is not an empty ritual, fulfilling its purpose of supervisory control.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT
367 ITR 112 · 2014 · High Court
225
citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Judgments citing reasons recorded

Rohit Prakashchandra Shah, Ahmedabad vs. The Income Tax Officer, Ward-1(2)(3), Ahmedabad

In the result, appeal preferred by the assessee is dismissed

ITA 128/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2014-15

Section 147Section 148

Prakashchandra Shah vs. ITO Page 4 of 22 under Section 147 of the Act should be adjudicated first. The Ld. AR submitted that the reason recorded by the Assessing Officer about the escapement of income was without availability of any information with the Assessing Officer. In this regard ... drawn our attention to the reasons recorded by the Assessing Officer and submitted that paragraph no.-3 of the reason was left blank, which revealed that there was no foundational fact or information available on record with the Assessing Officer. Therefore, the satisfaction recorded by the Assessing Officer was baseless

Gajiben Mahotji Thakor, Ahmedabad vs. The Income Tax Officer, Ward-3(3)(8), Ahmedabad

In the result, appeal filed by the assessee is dismissed

ITA 324/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2011-12

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri Ketan Shah, Advocate & ShriFor Respondent: Shri Abhijit, Sr.DR
Section 143(2)Section 147Section 148Section 151Section 250Section 45

therefore, there is no justification for confirming the addition. 6. In not appreciating the fact that, there is no such original copy of the reason recorded provided nor the copy of the approval u/s 151 as contended in para 11 and 12 in the appeal ord3er and therefore, the proceeding ... produce before us the copy of reasons given to the assessee which as per him were only an abstract of the reasons recorded by the AO. Ld. Counsel for the assessee was unable to produce the same before us. In the light of the same, since, the Ld. Counsel

Chhanda Kar, Tamluk vs. ITO, Ward 27(3), Haldia

Appeal of the assessee is allowed for statistical purposes

ITA 1343/KOL/2025[2015-2016]Status: DisposedITAT Kolkata30 Oct 2025AY 2015-2016

Bench: The Ld. Commissioner Of Income Tax (Appeals), Nfac Through E-Filling.

Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 250Section 253(3)Section 69

confirming the order of the AO, National Faceless Assessment Centre when the notice u/s 148 dated 20/03/2020 is bad in law since the reasons recorded along with copy of approval prior to the issue of the notice were not forwarded to the assessee and there was nothing on record

Kajal Batra, Delhi vs. ACIT, Circle-52(1), Delhi

In the result, the appeal of the assessee stands dismissed as above

ITA 2419/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 151Section 68Section 69A

order being beyond jurisdiction wrong and bad in law and on PAN No. AGQPB4318Q surrendered by the assessee appellant. 2. The appellant contends that reasons recorded has no nexus with the additions made by the AO in the impugned order u/s 147 of the Act. There is no approval ... erred in not appreciating that the final order of the AO making the addition has no nexus to the reasons recorded in so far as the addition is made on an altogether different reasoning not arising from the reasons recorded for the issue of notice u/s 148. Thus, the reassessment

Baani Landbase Private Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, appeal of the Assessee is allowed

ITA 5944/DEL/2024[2015-16]Status: DisposedITAT Delhi30 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.5944/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Baani Landbase Pvt Ltd., Dcit, Corporate One, Ground Floor, Vs. Circle-4(2), Plot No.5, District Center, Jasola, Central Revenue Building, Delhi. I.P. Estate, Delhi. Pan No.Aadcb0237E अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 154Section 156Section 292B

Subsequently notice u/s 148 was issued on 30.06.2021 which is placed at page 33 of the PB along with the approval and reasons recorded for reopening the assessment which are placed at pages 34 to 36. Ld. Counsel referring to page 35 of the Paper Book which are the reasons

Pr Commissioner of Income Tax Central 2 vs. M/S. Believe Constructions P. Ltd

ITA/555/2025HC Delhi29 Oct 2025

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Section 144Section 153Section 153ASection 153DSection 260A

relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer, that it is a fit case for the issue of such notice. (2) In a case other than a case falling under subsection ... issued under Section 148 by an Assessing Officer, who is below the rank of Joint Commissioner, unless the Joint Commissioner is satisfied, on the reasons recorded by such Assessing Officer, that it is a fit case for the issue of such notice. (3) For the purposes of sub-section

Atul Vrajlal Karia, Rajkot vs. Ac / Dc (Int.Txn), Rajkot

In the result, appeal filed by the assessee is allowed in above terms

ITA 133/RJT/2025[2012-13]Status: DisposedITAT Rajkot29 Oct 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.133/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2012-13 Atul Vrajlal Karia Ac/Dc (Int. Txn), बनाम C/O. D.S. Karia & Co. Ca, 203, Rajkot Cosmo Complex, Mahila College Vs. Chowk, Kalawad Road, Rajkot Pan : Adwpk6568J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

For Appellant: Shri Kalpesh Doshi, ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 127Section 147Section 148Section 151Section 153CSection 250Section 282Section 69

account of following counts: (a) The notice u/s 148 is issued beyond the time limit prescribed under the Act. (b) The reasons recorded for reopening the assessment is based on incorrect facts. (c) The reopening is made without "reason to believe", there is no live link between reasons recorded ... No.133 /RJT/2025 (AY : 2012-13) 3 (iv) The Ld. AO has passed the impugned order without a valid Document Identification Number (DIN): (v) The reasons recorded for reopening the assessment is based on incorrect facts. (vi) The reopening is made without "reason to believe", there is no live link between

Ramaben Maganlal Zalaria, Rajkot vs. The Principal Commissioner of Income Tax-1, Rajkot

ITA 276/RJT/2024[2015-16]Status: DisposedITAT Rajkot29 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 274 To 276/Rjt/2024 (Assessment Year: 2013-14 To 2015-16) (Hybrid Hearing) Ramaben Maganlal Zalaria, Vs. The Pcit-1, Umakant Udhyognagar, Near Rajkot 360001 Gandhiya Estate, Mavdi Plot, Rajkot-360004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacpz0156C (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 133ASection 147Section 148Section 263

Counsel for the assessee, argued that assessing officer has reopened the assessee's case based on the information received from the Department and in reasons recorded, the assessing officer mentioned that assessee had received cheque, however the Id. PCIT in his order stated that the assessee had received the cash ... therefore, there is no certainty in the reasons recorded by the assessing officer, as well as issue raised by the learned PCIT in his revision order. The learned PCIT believed that assessee had received cash, however, assessing officer believed that assessee had received cheque. Hence, issue raised by the learned

Ramaben Maganlal Zalaria, Rajkot vs. The Principal Commissioner of Income Tax-1, Rajkot

ITA 275/RJT/2024[2014-15]Status: DisposedITAT Rajkot29 Oct 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 274 To 276/Rjt/2024 (Assessment Year: 2013-14 To 2015-16) (Hybrid Hearing) Ramaben Maganlal Zalaria, Vs. The Pcit-1, Umakant Udhyognagar, Near Rajkot 360001 Gandhiya Estate, Mavdi Plot, Rajkot-360004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacpz0156C (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 133ASection 147Section 148Section 263

Counsel for the assessee, argued that assessing officer has reopened the assessee's case based on the information received from the Department and in reasons recorded, the assessing officer mentioned that assessee had received cheque, however the Id. PCIT in his order stated that the assessee had received the cash ... therefore, there is no certainty in the reasons recorded by the assessing officer, as well as issue raised by the learned PCIT in his revision order. The learned PCIT believed that assessee had received cash, however, assessing officer believed that assessee had received cheque. Hence, issue raised by the learned

Ramaben Maganlal Zalaria, Rajkot vs. The Principal Commissioner of Income Tax-1, Rajkot

ITA 274/RJT/2024[2013-14]Status: DisposedITAT Rajkot29 Oct 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 274 To 276/Rjt/2024 (Assessment Year: 2013-14 To 2015-16) (Hybrid Hearing) Ramaben Maganlal Zalaria, Vs. The Pcit-1, Umakant Udhyognagar, Near Rajkot 360001 Gandhiya Estate, Mavdi Plot, Rajkot-360004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacpz0156C (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 133ASection 147Section 148Section 263

Counsel for the assessee, argued that assessing officer has reopened the assessee's case based on the information received from the Department and in reasons recorded, the assessing officer mentioned that assessee had received cheque, however the Id. PCIT in his order stated that the assessee had received the cash ... therefore, there is no certainty in the reasons recorded by the assessing officer, as well as issue raised by the learned PCIT in his revision order. The learned PCIT believed that assessee had received cash, however, assessing officer believed that assessee had received cheque. Hence, issue raised by the learned

Sathyanarayana Saka, Someswaram vs. Assessing Officer, Kakinada

In the result, appeal of the assessee in ITA No

ITA 488/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam29 Oct 2025AY 2015-16

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 131Section 139Section 147Section 148Section 69A

date provided under Section 139 of the Income Tax Act. The assessment was subsequently reopened under Section 147 of the Act, for the reasons recorded, as per which income chargeable to tax had escaped assessment on account of unexplained source for cash deposits into bank account maintained with ICICI Bank

Sathyanarayana Saka, Someswaram vs. Assessing Officer, Kakinada

In the result, appeal of the assessee in ITA No

ITA 487/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam29 Oct 2025AY 2014-15

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 131Section 139Section 147Section 148Section 69A

date provided under Section 139 of the Income Tax Act. The assessment was subsequently reopened under Section 147 of the Act, for the reasons recorded, as per which income chargeable to tax had escaped assessment on account of unexplained source for cash deposits into bank account maintained with ICICI Bank

Satish Vishnu Thombare, Income Tax Officer, Ward-1, Ahmednagar vs. Varsha Prafulla Zende, Ahmednagar

In the result, the appeal of the Revenue is dismissed

ITA 1656/PUN/2024[2010-11]Status: DisposedITAT Pune29 Oct 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

For Appellant: Miss Shivani Shah (Virtual)For Respondent: Shri Akhilesh Srivastva
Section 132(1)Section 147Section 148Section 151Section 68

notice u/s 148 of the Act, the Tribunal held that the initiation of the reassessment proceedings was done on the basis of the incorrect reasons recorded and accordingly the notice issued u/s 148 of the Act was bad in law. As regards, the second issue relating to the non-compliance ... assessee allowed the appeal of the assessee holding that notice u/s 148 of the Act is issued on the basis of incorrect reason recorded and reassessment proceedings was initiated without complying with the requirement of section 151 of the Act. The relevant findings and observations

Pullarao Perugu, Ongole vs. ITO., Ward-1, Ongole

In the result, the appeal of assessee in ITA

ITA 1132/HYD/2024[2017-18]Status: DisposedITAT Hyderabad29 Oct 2025AY 2017-18

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 142(1)Section 144(1)(b)Section 147Section 148Section 249(3)Section 271A

income for the assessment year 2017-18. The assessment has been reopened under Section 147 of the Income Tax Act, 1961 for the reasons recorded, as per which income chargeable to tax has been escaped assessment on account of cash deposits in current account to the extent

Pulla Rao Perugu, Prakasam vs. Income Tax Officer, Ward-1, Ongole

In the result, the appeal of assessee in ITA No

ITA 1035/HYD/2024[2017-18]Status: DisposedITAT Hyderabad29 Oct 2025AY 2017-18
Section 142(1)Section 144(1)(b)Section 147Section 148Section 249(3)Section 271A

income for the assessment year 2017-18. The\nassessment has been reopened under Section 147 of the Income\nTax Act, 1961 for the reasons recorded, as per which income\nchargeable to tax has been escaped assessment on account of\ncash deposits in current account to the extent

ACIT, New Delhi vs. Vrinda Farms Private Limited, New Delhi

In the result, the appeal of the Revenue as well as cross objections of the assessee are dismissed

ITA 4849/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Central Circle 4, Vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) Co Nos.13 & 19/Del/2025 (In Ita No.4849/Del/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, Vs. Acit, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 29.10.2025 Order Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short]

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 132(4)Section 133(6)Section 68

return of income was filed on 14.07.2021. Thereafter, due enquiries were made by the AO and no addition was made on account of the reasons recorded and therefore, AO has no jurisdiction to make any other addition. For this, he placed reliance on the judgement of Hon’ble Jurisdictional High ... case of ATS Infrastructure Ltd. vs ACIT reported in [2025] 166 taxmann.com 61 (Delhi) has that AO cannot be permitted to improve the reasons recorded which form basis for initiating action under section 148A. The relevant observations of the hon’ble high court as contained in para

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4671/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

paper book. 5. At the time of hearing, ld. AR of the assessee brought to our notice above CO Nos.126, 104 & 105/Del/2025 reasons recorded for issuing notice u/s 148 of the Act and subsequently assessee filed objections against the above reasons recorded by the AO and further he brought ... based on which he has completed the issues making advantage on the basis of modified reasons during the assessment proceedings. He submitted that the reason recorded by the AO is factually incorrect and legally invalid. In this regard, he submitted that the entire foundation of the reopening was based

DCIT, Circle - 10(1), New Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4670/DEL/2024[2015-16]Status: DisposedITAT Delhi29 Oct 2025AY 2015-16

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

paper book. 5. At the time of hearing, ld. AR of the assessee brought to our notice above CO Nos.126, 104 & 105/Del/2025 reasons recorded for issuing notice u/s 148 of the Act and subsequently assessee filed objections against the above reasons recorded by the AO and further he brought ... based on which he has completed the issues making advantage on the basis of modified reasons during the assessment proceedings. He submitted that the reason recorded by the AO is factually incorrect and legally invalid. In this regard, he submitted that the entire foundation of the reopening was based

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4669/DEL/2024[2011-12]Status: DisposedITAT Delhi29 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 148

paper book. 5. At the time of hearing, ld. AR of the assessee brought to our notice above CO Nos.126, 104 & 105/Del/2025 reasons recorded for issuing notice u/s 148 of the Act and subsequently assessee filed objections against the above reasons recorded by the AO and further he brought ... based on which he has completed the issues making advantage on the basis of modified reasons during the assessment proceedings. He submitted that the reason recorded by the AO is factually incorrect and legally invalid. In this regard, he submitted that the entire foundation of the reopening was based

Omkar Singh, Noida vs. ITO Ward - 5(2)(1), Noida

In the result, the appeal of the assessee is allowed

ITA 3574/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Oct 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 115BSection 139(1)Section 143(2)Section 147Section 148Section 151Section 69A

A.Y.2017-18’, however the assessee has duly filed the return of income on 15.09.2017 for the year under consideration. Further submitted that, the reasons recorded by the AO is contrary to the fact and in a mechanical manner,wherein not examined so called information and not broughton record the evidence from ... grounds should be decided, and then the case should be decided, but the Hon'ble Bench has heard the matter on the basis of reasons recorded by the AO. It is observed in one other case, which was presented by me, that the Hon'ble Bench allowed the filing