https://www.taxtmi.com/caselaws?id=6917 An assessment order refusing registration of an assessee-firm must be read as a whole and construed by substance rather than title. The order here expressly stated that assessment was completed under section 23(4) and that registration was refused in the exercise of discretion under that provision, even though it was also described by reference to section 26A and contained no recorded reasons. The absence of reasons did not negate exercise of discretion, and the powers under section 23(4) and section 26A were distinct and capable of operating together. On that construction, the refusal of registration was supportable under both provisions. en-us Thu, 22 Jun 1967 00:00:00 +0530 Sat, 07 Feb 2009 08:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6917 An assessment order refusing registration of an assessee-firm must be read as a whole and construed by substance rather than title. The order here expressly stated that assessment was completed under section 23(4) and that registration was refused in the exercise of discretion under that provision, even though it was also described by reference to section 26A and contained no recorded reasons. The absence of reasons did not negate exercise of discretion, and the powers under section 23(4) and section 26A were distinct and capable of operating together. On that construction, the refusal of registration was supportable under both provisions. Case-Laws Income Tax Thu, 22 Jun 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6917