2015 (6) TMI 1165

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..... The giving of reasons in support of the conclusions by judicial and quasi judicial authorities when exercising initial jurisdiction is essential for various reasons. First it is calculated to prevent unconscious, unfairness or arbitrariness in reaching the conclusions. The very search for reasons will put the authority on the alert and minimize the chances of unconscious infiltration of actual bia .....

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..... nexure-G, of the Deputy Commissioner of Income Tax, Circle 12(4), Bangalore, invoking Section 147 of the Income Tax Act, for the assessment year 2009-10, is said to have been supplied the reasons for reopening the case by communication, dated 06.06.2014, Annexure-H, following which petitioner filed its objections, by way of a letter, dated 12.06.2014, Annexure-J, where afterwards, the Deputy Commi .....

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..... rt in Woolcombers of India Ltd., vs. Woolcombers workers Union and another AIR 1973 SC 2758. 3. The communication, Annexure-K, simply states that the objections are rejected, since the licence fee/logo is a expenditure towards good will . This, in my considered opinion, is a conclusion and not a reason . In the circumstances, there is a need to interfere with the communication, Annexure-K. .....

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