2005 (1) TMI 15

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..... ENT The judgment of the court was delivered by Arijit Pasayat J. - Leave granted. These appeals by the assessee are directed against the judgment rendered by a Division Bench of the Karnataka High Court (see [2003] 264 ITR 142) in appeals purported to be under section 260A of the Income-tax Act, 1961 (in short "the Act"). The appeals were filed by the Revenue questioning the correctness of cert .....

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..... y allowed the appeals filed by the Revenue in part. The basic issues which form the core dispute have been dealt with in the appeals filed by the assessees and disposed of, as noted supra, today. Learned counsel for the appellant submitted that the conclusions of the High Court have been arrived at without any discussion and the reasons have not been indicated as to why the seal of approval was b .....

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..... . Reasons for affirmation have to be indicated, though in appropriate cases they may be briefly stated. Recording of reasons is a part of fair procedure. Reasons are the harbinger between the mind of the maker of the decision in the controversy and the decision or conclusion arrived at. They substitute subjectivity with objectivity. As observed in Alexander Machinery (Dudley) Ltd. v. Crabtree [19 .....

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