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The HC upheld the Principal Commissioner's suo motu revision under Section 263 of the Income Tax Act, allowing limited remand to the AO. The Court found the AO's rejection of the assessee's claims on seven of nine remitted points was without recorded reasons, rendering the order legally invalid. Emphasizing the mandatory requirement to provide reasoned orders, the Court held that absence of reasons violates principles of fairness and transparency, impeding effective judicial scrutiny and the assessee's right to know grounds for disallowance. Consequently, the impugned order was quashed, and the matter remanded to the AO for fresh adjudication of the seven points with proper reasoning and opportunity for hearing, directing completion within three months.
The HC upheld the Principal Commissioner's suo motu revision under Section 263 of the Income Tax Act, allowing limited remand to the AO. The Court found the AO's rejection of the assessee's claims on seven of nine remitted points was without recorded reasons, rendering the order legally invalid. Emphasizing the mandatory requirement to provide reasoned orders, the Court held that absence of reasons violates principles of fairness and transparency, impeding effective judicial scrutiny and the assessee's right to know grounds for disallowance. Consequently, the impugned order was quashed, and the matter remanded to the AO for fresh adjudication of the seven points with proper reasoning and opportunity for hearing, directing completion within three months.
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