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TMI Blog2020 (9) TMI 576X X X X Extracts X X X X X X X X Extracts X X X X ..... g of the Lower Appellate Authority and why the grounds raised by the assessee cannot be entertained. Since the order is devoid of reasons, we are constrained to interfere with the impugned order to the extent indicated and remand the matter back to the Tribunal for fresh consideration - above two issues are set aside and remanded to the Tribunal for fresh consideration. - T.C.A. No. 947 of 2019 - - - Dated:- 5-8-2020 - THE HONOURABLE MR.JUSTICE T.S.SIVAGNANAM And THE HONOURABLE MRS.JUSTICE V.BHAVANI SUBBAROYAN For the Appellant : Mr.R.Vijayaraghavan, Senior Counsel for Ms.Subbaraya Aiyar Padmanabhan For the Respondent : Ms.R.Hemalatha Senior Standing counsel JUDGMENT [ Order of the Court was made by T. S. SIVAGNAN ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the matter. We say so because the Tribunal has not rendered any finding as to why the grounds raised by the assessee cannot be decided in their favour. The two contentions which are subject matter of this appeal are reopening of the assessment under Section 147 of the Act and the second issue is with regard to the computation of deduction under Section 80M of the Act. 3. To be noted that the assessee has succeeded on merits and this appeal has pursued by the assessee only on the above mentioned two grounds. We note that the following were the grounds of appeal raised by the assessee before the Tribunal on the aforementioned two issues: i. The learned CIT(A) had erred in confirming the order of assessing officer in reopening the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Tribunal in respect of the second ground is as follows: 14. After hearing the rival submissions, we find that the learned Authorised Representative has not controverted the findings of the learned Commissioner of Income Tax (A) that this ground does not arise out of the order of reassessment of the learned Assessing Officer. Therefore, the ground of appeal of the assessee is dismissed. 6. A bare reading of the above shows that the Tribunal has not given any independent reasons as to why the grounds canvassed by the assessee before the Tribunal does not merit consideration. The Tribunal is required to record reasons as to why there is disagreement with the finding of the Lower Appellate Authority and why the grounds raised by th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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