TMI Blog2024 (1) TMI 556X X X X Extracts X X X X X X X X Extracts X X X X ..... he conclusions of the assessing officer and rejected the appeal - HELD THAT:- On examining the impugned order, we find that the appellate authority has set out the grounds raised by the appellant, the written submissions of the appellant and the inferences and conclusions drawn by the assessing officer. The appellate authority has drawn the conclusion that the inferences and findings of the assessing officer are acceptable. However, there is nothing to indicate that the appellate authority independently applied his mind. The conclusions are in the nature of ipse dixit and no supporting reasons are discernible. On this sole ground, albeit without expressing any opinion on the merits of the matter, we inclined to interfere with the appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Learned counsel for the petitioner invited my attention to the appellate order and pointed out that the appellate authority reproduced the grounds of appeal, the facts of the case, the written submissions of the appellant and the inferences and conclusions drawn by the assessing officer. Thereafter, learned counsel submits that the findings and conclusions were recorded in one paragraph, which contains no reasons in support of such conclusions. 4. Dr.B.Ramasamy, learned senior standing counsel (IT), accepts notice on behalf of the respondents. He submits that the impugned order does not call for any interference and that the said order is supported by reasons. In support of this conclusion, he refers to the inferences recorded in the i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the appellate authority has drawn the conclusion that the inferences and findings of the assessing officer are acceptable. However, there is nothing to indicate that the appellate authority independently applied his mind. The conclusions are in the nature of ipse dixit and no supporting reasons are discernible. On this sole ground, albeit without expressing any opinion on the merits of the matter, I am inclined to interfere with the appellate order. 6. Consequently, W.P.No.36018 of 2023 is allowed by quashing the impugned order dated 11.10.2023. As a corollary, the matter is remanded for reconsideration by the appellate authority. After providing a reasonable opportunity to the petitioner, the appellate authority is directed to dis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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