2024 (1) TMI 556

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....t Petition No. 36018 of 2023 And W. M. P. Nos. 35994 & 35995 of 2023 - -<br>Income Tax<br>Honourable Mr. Justice Senthilkumar Ramamoorthy For the Petitioner : Mr.Joseph Prabakar For the Respondents : Dr.B.Ramasamy, Sr. Standing Counsel (IT) ORDER The petitioner assails the appellate order dated 11.10.2023 by which the Commissioner of Income Tax (Appeals) rejected the appeal filed by th....

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.... income in the relevant assessment year. The appellate authority accepted all the conclusions of the assessing officer and rejected the appeal. The present writ petition arises in the said facts and circumstances. 3. 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,....

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....ppellant, the written submissions of the appellant and the inferences and conclusions drawn by the assessing officer. After setting out the above, the findings and decisions are recorded in a brief paragraph. The said paragraph is set out below: "6.2 Findings and decision: I have carefully considered the facts of the case as well as submissions filed by the appellant. I find no f....

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....appeal no.4 and 6 are dismissed. " From the above extract, it follows that 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 s....