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In meeting objections to the reopening the AO is bound by law to pass a reasoned order. The Bombay High Court in [2022] 443 ITR 411 held that the AO has to deal with each and every objection raised by the taxpayer by recording reasons and cannot pass the order in a very casual way as in this case no reasons were recorded in the impugned order while dealing with the objections of the taxpayer. In this case the AO defended notice issued u/s 148 over 153C without any reason or justification. 


Citing previous ruling on meaningful reasoning the Court held that if the reasons make reference to any other document or a letter or a report, such document or letter or report should be enclosed to the reasons. The order disposing of the objections should deal with each objection and give proper reasons for the conclusion.

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