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    Adequate enquiry limits section 263 revision; shareholder funding and commercially expedient purchases may avoid tax adjustments
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      Reasoned and speaking administrative orders are required by...

      Reasoned administrative orders are essential to natural justice; unreasoned stay rejections require fresh determination through speaking orders.

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      Income TaxJuly 24, 2026Case LawsHC
      Reasoned and speaking administrative orders are required by natural justice, particularly when rejecting stay applications. Recording reasons replaces subjective decision-making with objective assessment, and the obligation applies to administrative authorities as well as judicial bodies. An unreasoned rejection of a stay application cannot be sustained because it prevents meaningful scrutiny of the decision. The stay-rejection orders were therefore quashed, and the competent authority was directed to determine the stay applications afresh through reasoned and speaking orders.

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      ActsIncome Tax