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Ocean Sparkle Limited,Hyderabad vs Dcit., Circle-5(1), Hyderabad on 7 November, 2025

(Para 51) The contention of the Revenue that the AO had not applied his mind to the material on record cannot be accepted because the CIT in his order specifically records a finding that there is application of mind by the AO. The Revenue cannot raise a plea which is not contained in the order of the CIT and is contrary to it and to the record. The contention of the Revenue that there are no reasons given by the AO about the nature of activity of the assessee cannot be accepted because a query was raised by him in the course of the assessment proceedings and was replied by the assessee. Obviously, he was satisfied with the explanation of the assessee and therefore did not think that the issue needs to be specifically mentioned. It is settled law that the AO in the assessment order is not required to give detailed reasons and once it is clear that there was application of mind by an enquiry, the CIT, merely because he entertains a different opinion in the matter, cannot invoke his powers under s. 263. It is therefore not correct to say that there was no proper enquiry by the AO.-P.V.S. Raju & Ors. vs. Addl. CIT (2012) 247 CTR (AP) 583: (2012) 67 DTR (AP) 272: (2012) 340 ITR 75 (AP) distinguished.
Income Tax Appellate Tribunal - Hyderabad Cites 24 - Cited by 0 - Full Document

Smt. Lalita vs State And Ors on 24 January, 2022

9. In support of his contention that the limitation period to challenge allotment of the said land in question was over, the (D.B. SAW/1042/2008 has been filed in this matter. Please refer the same for further orders) (Downloaded on 28/01/2022 at 08:20:13 PM) (6 of 9) [CW-8423/2008] learned counsel for the petitioner cites at the bar, the following judgments, rendered by this Court in Murali and Anr. Vs. Addl.
Rajasthan High Court - Jodhpur Cites 5 - Cited by 0 - P S Bhati - Full Document

Shiv Narayan vs State And Ors on 24 January, 2022

9. In support of his contention that the limitation period to challenge allotment of the said land in question was over, the (D.B. SAW/1139/2008 has been filed in this matter. Please refer the same for further orders) (Downloaded on 28/01/2022 at 08:20:14 PM) (6 of 9) [CW-8423/2008] learned counsel for the petitioner cites at the bar, the following judgments, rendered by this Court in Murali and Anr. Vs. Addl.
Rajasthan High Court - Jodhpur Cites 5 - Cited by 0 - P S Bhati - Full Document

Smt. Sushila Bai vs State And Ors on 24 January, 2022

9. In support of his contention that the limitation period to challenge allotment of the said land in question was over, the (D.B. SAW/1100/2008 has been filed in this matter. Please refer the same for further orders) (Downloaded on 28/01/2022 at 08:20:16 PM) (6 of 9) [CW-8423/2008] learned counsel for the petitioner cites at the bar, the following judgments, rendered by this Court in Murali and Anr. Vs. Addl.
Rajasthan High Court - Jodhpur Cites 5 - Cited by 0 - P S Bhati - Full Document

Smt. Radha Devi vs State And Ors on 24 January, 2022

9. In support of his contention that the limitation period to challenge allotment of the said land in question was over, the (D.B. SAW/1041/2008 has been filed in this matter. Please refer the same for further orders) (Downloaded on 28/01/2022 at 08:20:11 PM) (6 of 9) [CW-8423/2008] learned counsel for the petitioner cites at the bar, the following judgments, rendered by this Court in Murali and Anr. Vs. Addl.
Rajasthan High Court - Jodhpur Cites 5 - Cited by 0 - P S Bhati - Full Document

Smt. Sunita Bai vs State And Ors on 24 January, 2022

9. In support of his contention that the limitation period to challenge allotment of the said land in question was over, the (D.B. SAW/1044/2008 has been filed in this matter. Please refer the same for further orders) (Downloaded on 28/01/2022 at 08:20:12 PM) (6 of 9) [CW-8423/2008] learned counsel for the petitioner cites at the bar, the following judgments, rendered by this Court in Murali and Anr. Vs. Addl.
Rajasthan High Court - Jodhpur Cites 5 - Cited by 0 - P S Bhati - Full Document

Smt. Geeta Bai vs State And Ors on 24 January, 2022

9. In support of his contention that the limitation period to challenge allotment of the said land in question was over, the (D.B. SAW/1043/2008 has been filed in this matter. Please refer the same for further orders) (Downloaded on 28/01/2022 at 08:20:15 PM) (6 of 9) [CW-8423/2008] learned counsel for the petitioner cites at the bar, the following judgments, rendered by this Court in Murali and Anr. Vs. Addl.
Rajasthan High Court - Jodhpur Cites 5 - Cited by 0 - P S Bhati - Full Document
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