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2016 (3) TMI 328 - HC - Income TaxReopening of assessment - sanction u/s.151(2) from the competent authority - whether the Additional C.I.T. while according his approval u/s.151(2) of the Act did not apply his mind and mechanically granted sanction? - Held that:- In the instant case the assessee has not even contended that the reasons recorded by the assessing officer were irrelevant and as such he had no reason to believe that any income chargeable to tax had escaped assessment. In R.P. Bhatt (1986 (12) TMI 372 - SUPREME COURT) the Apex Court relied on judgment rendered by a Constitutional Bench in the case of Som Datt Datta v. Union of India [1968 (9) TMI 113 - SUPREME COURT OF INDIA ] wherein their lordships held that apart from any requirement imposed by the statute or statutory rule either expressly or by necessary implication, there is no legal obligation that the statutory tribunal should give reasons for its decision. There is also no general principle or any rule of natural justice that a statutory tribunal should always and in every case give reasons in support of its decision. - Decided in favour of the revenue.
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